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HomeMy WebLinkAbout25D - AGMT RECORDKEEPING SVC 457 PLANREQUEST FOR COUNCIL ACTION CITY COUNCIL MEETING DATE: JULY 17, 2018 TITLE: APPROVE AN AGREEMENT WITH PRUDENTIAL RETIREMENT INSURANCE AND ANNUITY COMPANY FOR ADMINISTRATIVE, RECORDKEEPING AND COMMUNICATION SERVICES PERTAINING TO THE 457 DEFERRED COMPENSATION PLAN (STRATEGIC PLAN NO. 7,4) i Cn MANAGER RECOMMENDED ACTION CLERK OF COUNCIL USE ONLY: ❑ As Recommended ❑ As Amended ❑ Ordinance on V Reading ❑ Ordinance on 2ntl Reading ❑ Implementing Resolution ❑ Set Public Hearing For CONTINUED TO FILE NUMBER 1) Authorize the City Manager and Clerk of the Council to execute an agreement with Prudential Retirement Insurance and Annuity Company ('Prudential') for the administrative, recordkeeping and communication services ("services") pertaining to the 457 Deferred Compensation Plan for an initial three-year term beginning October 1, 2018 through September 30, 2021, with a provision for a two-year extension exercisable by the City Manager and the City Attorney, subject to non -substantive changes approved by the City Manager and the City Attorney. 2) Authorize the City Manager and Clerk of the Council to execute the trust agreement with Prudential Bank and Trust, FSB for trustee services related to the 457 Deferred Compensation Plan for an initial three-year term beginning October 1, 2018 through September 30, 2021, with a provision for a two-year extension exercisable by the City Manager and the City Attorney, subject to non -substantive changes approved by the City Manager and the City Attorney. DISCUSSION The City of Santa Ana offers full-time employees a 457 Deferred Compensation Plan ("plan" or "457 plan"), which was established in 1973, with the adoption of City Resolution 7-21, along with a corresponding US Internal Revenue Service approval. The plan is a voluntary deferral program that is separate and distinct from the CaIPERS pension system. Specifically, the establishment of this plan, pursuant to regulations in §457 of the Internal Revenue Code, provides participants an opportunity to supplement their CaIPERS retirement by allowing them to defer a portion of their own current earnings. 2513-1 Agreement with Prudential for Administration of 457 Deferred Compensation Plan July 17, 2018 Page 2 Administration (Due Diligence) Currently, the 457 Deferred Compensation Plan is administered through the Finance & Management Services Agency. Management of the account consists of oversight by the Plan Administrative and Investment Committee ("Committee"), which includes, but not limited to: quarterly performance review of investments, analyzing the Plan's fund line-up, maintaining and revising, when necessary, the Plan's Investment Policy Statement, and ensuring the Plan's cost effectiveness. The Committee is comprised of the Executive Director of Finance, the Assistant Finance Director, the Treasury Manager and a Budget Analyst. The Committee utilizes a third party consultant, Benefits Financial Services Group ("BFSG") to assist in reviewing investments, compliance and fund selection. BFSG assisted the City in the development of the current RFP and evaluation of the pricing structure of proposals. As of June 30, 2018, the Plan holds $113.5 million in Plan Assets for 1,170 participants. Request for Proposals On December 19, 2017, the City Council authorized staff to issue a Request for Proposals ("RFP") for the administrative, recordkeeping and communication services, such as, providing the investment platform, ensuring Plan compliance with federal regulations and offering various other participant services (i.e., educational seminars, financial planning, on-site consultation & website services). On February 28, 2018, an RFP (RFP No. 18-025) for the aforementioned services was issued by BFSG. Nine proposals were received and evaluated by the Committee, with assistance from BFSG. Vendors were evaluated based on the following criteria: 1) Recordkeeping and Administration (15 pts); 2) Client & Participant Services (15 pts); 3) Communication & Education (25 pts); 4) Investment Platform (25 pts); and 5) Plan Provider Fees (20 pts); Four finalists were selected. The finalists were invited to attend an in-person interview and demonstration to provide an overview of more specific services, such as educational services, website services, the proposed investment strategies and proposed plans to address the market to book value for one of the Plan's investment option. The vendors were ranked accordingly, as follows: Rank Firm Comprehensive Analysis out of 100points) 1 Prudential 92.1 2 Nationwide 84.1 3 Empower 83.5 4 MassMutual 79.3 25D-2 Agreement with Prudential for Administration of 457 Deferred Compensation Plan July 17, 2018 Page 3 Prudential's proposal met the Committee's requirements and needs in all areas. The cost structure presented by Prudential offers a cost effective platform for all participants, is consistent with other vendors and provides the best value to the Plan. Prudential will provide an enhanced participant experience through its emphasis on participant education and financial planning and through its comprehensive and flexible investment options. In particular, Prudential presented a more proactive approach to data analysis and participant engagement in comparison to other vendors. Additionally, Prudential will continue to support the Plan's open architecture investment platform and will provide forty-eight educational days along with ten financial planning days per year. The proposed agreement will allow for greater expansion of fund selection and flexible liquidity restrictions while significantly reducing Plan Provider fees from 10 basis points to 4.9 basis points or approximately 104% reduction in fees. Prudential will also provide participants with an asset allocation model ("Goalmaker') at no cost and an on-site financial planner, which will assist participants in determining investment options. STRATEGIC PLAN ALIGNMENT Approval of this item allows the City to meet Goal #7 Team Santa Ana, Objective #4 (Establish employee compensation that attracts and retains a highly qualified workforce). FISCAL IMPACT There is no fiscal impact associated with this action. All administrative fees pertaining to the services will be borne by the plan participants. Internal Revenue Code permits administrative reimbursement from plan assets, which will be utilized to offset fiduciary advisory, participant education and staffing costs related to the management of the 457 Plan. �(�ftcv�n�j�r� lel Francisco Gutierrez Executive Director Finance and Management Services Agency EXHIBITS: 1. 457 Services Agreement 2. Trust Agreement 3. Investment Agreement AC 25D-3 25D-4 Prudential SERVICES AGREEMENT ("Agreement") Effective as of October 1, 2018 by and between CITY OF SANTA ANA ("Plan Sponsor") and Services Agreement Provided by Prudential Retirement Insurance and Annuity Company PRUDENTIAL RETIREMENT INSURANCE AND ANNUITY COMPANY ("Prudential") on behalf of the City of Santa Ana Deferred Compensation Plan ('Plan") As used in this Agreement, "Plan Sponsor" shall also mean any agent, representative or designee the Plan Sponsor authorizes to act for it with Prudential, and 'Prudential" shall also mean any agent, designee or subcontractor Prudential authorizes to act for it. The Plan Sponsor agrees and acknowledges that the services provided hereunder may be provided by or through affiliates or subsidiaries of Prudential, including, but not limited to, Prudential Investment Management Services LLC ("PIMS"). A. Basic Understandings The Plan Sponsor represents that: • The Plan is or will be in existence at the time funds are deposited with Prudential; • The Plan is intended to be an eligible deferred compensation plan described in Section 457(b) of the Internal Revenue Code of 1986, as amended (the "Code") for a governmental employer described in Section 457(e)(1)(A) of the Code; • The Plan is funded by a related Trust (the 'Trust") which is intended to satisfy the requirements of Section 457(g) of the Code; and • It is authorized to execute this Agreement under the terms of the Plan. Prudential represents that: It will perform the Services (as defined herein) in accordance with its then current standard policies and procedures, described in the Administration Section of your Implementation Workbook ("Administrative Procedures'), as may be updated from time to time, and applicable law. Exhibit 1 2501-5 Wrob Prudential Mor B. Nature of Services Services Agreement Provided by Prudential Retirement Insurance and Annuity Company 1. Non -discretionary Services Only. The Plan Sponsor agrees and acknowledges that under this Agreement, Prudential provides non -discretionary administrative services at the direction of the Plan Sponsor, and may provide investment or other services as directed by the Plan Sponsor ("Services'). Plan Sponsor agrees and acknowledges it is responsible for obtaining the services of other service providers necessary for the maintenance of the Plan, including but not limited to attorneys, accountants, investment advisers and auditors. In performing the Services, Plan Sponsor agrees and acknowledges that Prudential (i) does not render investment advice, is not the Plan administrator, trustee or a Plan fiduciary, (ii) is not recommending an action nor acting as an advisor to the Plan or Plan Sponsor and does not owe a fiduciary duty pursuant to Section 15B of the Securities Exchange Act of 1934, and (iii) does not provide legal, tax or accounting advice with respect to the creation, adoption or operation of the Plan dnu any uusi tar the Haan tine' i iusi ). Hiuueuual reseives the tight, wan wasunable nouce, to decline to perform any service inconsistent with the previous sentence. 2. Reliance Upon Plan Sponsor Directions, Plan Data and Plan Document. All Services shall be provided based on information supplied by the Plan Sponsor, a Plan participant, beneficiary of a Plan participant or employee of the Plan Sponsor (collectively "Participant") (where the Plan provides for Participant direction). The Plan Sponsor agrees and acknowledges it is solely responsible to timely provide or confirm accurate, consistent and complete Plan data, Plan terms, and instructions in the format specified by Prudential, which Prudential will rely upon to deliver its Services. Prudential shall be under no obligation to perform any Services until it receives such information. For these purposes, "Plan data" means all data and records supplied to Prudential, obtained by Prudential, or required to perform the Services. Prudential shall provide Services in conformance with the terms of the most recent signed Plan document provided to Prudential, including any amendments thereto or any written explanations or interpretations of Plan terms provided by the Plan Sponsor. Any matters requiring interpretation of Plan terms or the exercise of discretion will be submitted to the Plan Sponsor for review and direction, and Prudential shall be under no obligation to take any further action until it receives the requested direction from the Plan Sponsor. Plan Sponsor agrees and acknowledges that Prudential's responsibilities under this Agreement will be carried out solely with regard to the assets of the Plan and Plan Data maintained on Prudential's recordkeeping systems. In performing the Services listed in Exhibit A, Prudential shall be under no obligation to take into consideration assets and/or data maintained by other service providers of the Plan, unless specifically agreed to in writing. 3. Reliance Upon Named Administrators and Trustees. The Plan Sponsor will provide names and other information for persons authorized to take or direct actions for or provide and receive information on behalf of the Plan and Trust. Prudential shall assume that those persons continue to be authorized until notified otherwise. The Plan Sponsor is solely responsible for the direct or Indirect consequences of actions or omissions resulting from instructions, confirmations, or approvals that Prudential reasonably understands to be authorized. 4. Use of Agents or Subcontractors. Prudential may use agents or subcontractors to perform any of the Services, but such use will not relieve Prudential of responsibility for proper provision of those Services. 25D-6 VON Prudential C. Compensation Services Agreement Provided by Prudential Retirement Insurance and Annuity Company 1. Direct Fees. Prudential's fees for the Services will be set at 4.9% bps. The Plan Sponsor agrees the Plan will be liable to pay Prudential directly for Services rendered in accordance with the approved fee. The Plan Sponsor agrees that all fees not deducted directly from Participant accounts will be paid by the Plan within thirty (30) days of the date of an invoice timely presented, unless fees are paid within that time by the Plan Sponsor. If the Plan Sponsor does not pay or direct Prudential to charge the Plan for fees within thirty (30) days, the Plan Sponsor authorizes Prudential to collect direct fees from the Plan's forfeiture account, if permitted by the Plan. If the amount in the forfeiture account is Insufficient to pay all such fees, Prudential will present the Plan Sponsor with an invoice for the unpaid balance, which shall be payable immediately upon receipt. Hossioie tees to Pruoenuai and Aliwates. i tie Han 6ponsor acknowiedges inat Nruuenuai may ue deemed to benefit from advisory and other fees paid to it or its affiliates for managing, selling, or settling of the Prudential mutual funds and other investment products or securities offered by Prudential or its affiliates, and further acknowledges that Prudential may benefit directly from the difference between investment earnings of Prudential stable value funds and the amount credited to deposits in those funds. Prudential may also benefit from broker-dealer or other entities' co- sponsorship of Prudential conferences. In addition, the Plan Sponsor acknowledges that associated persons of Prudential Retirement's affiliated broker-dealer receive greater compensation for client assets allocated to proorietary investment options. 3. Compensation to Third Parties. Commissions ranging from 0.0% to 1.0% will be paid in connection with deposits made to a group annuity contract issued by Prudential. The Plan Sponsor acknowledges that the broker dealer selling the investment products and services to the Plan. If any, may be compensated, directly or indirectly, by the principal underwriter of the mutual fund, by an affiliate of the collective trust or by the executing broker dealer in connection with self-directed brokerage accounts. Such compensation may include preferred provider payments, retail rollover payments, payment of broker expenses in connection with Prudential training and educational meetings or other variable payments. 4. Possible Additional Compensation/Loss. In certain circumstances (such as trading errors or delays), market trades may occur at times when the share price of the trade is not the price assured to the Plan and Participants. Prudential will net any pricing differences that occur and absorb any net loss and retain any net gain that results; provided, however, that the Plan Sponsor will be responsible for any net loss resulting from incorrect information it provides to Prudential, and Prudential will not absorb any such loss. The Plan Sponsor agrees and acknowledges that Prudential will retain any net gain that results as additional compensation for Services rendered. Additional information may be found in the Disclosure section of your Implementation Workbook. 5. Float Earnings. Plan Sponsor agrees and acknowledges that Prudential may earn additional compensation in the form of'Float" earnings on contributions and on distributions and loans. Prudential describes this compensation in its written float policy located in the Disclosures section of the Implementation Workbook. 6. Production of Documents. The charges under this Agreement do not include Prudential's fees, costs and expenses, including legal expenses, associated with considering or responding to requests for documents, providing testimony, or participating in legal or regulatory proceedings as a result of the performance of the Services. Prudential shall invoice Plan Sponsor separately, and Plan Sponsor agrees to reimburse Prudential for such reasonable fees, costs and expenses. D. Amendment or Termination of Agreement; Successor Recordkeeper 3 25D-7 Services Agreement WIN Prudential Provided by Prudential Retirement Insurance and Annuity Company 1. Termination. Each party may terminate this Agreement upon sixty (60) days prior written notice to the other. If any fees remain due at the time this Agreement is terminated, the Plan Sponsor directs Prudential to deduct such amounts from assets of the Plan available for transfer to the successor recordkeeper, unless the Plan Sponsor pays such fees before the scheduled transfer date. Such amounts will be deducted as a lump sum from the assets available for transfer, and therefore will not be allocated to individual Participant accounts. In the event that the Plan Sponsor terminates this Agreement before commencement of Services for any reason, the Plan Sponsor agrees to reimburse Prudential for any reasonable out-of-pocket expenses which Prudential incurs in connection with the transition. 2. Successor Recordkeeoer. Payouts. The parties agree that upon termination Prudential will have no further duty or responsibility to the Plan under this Agreement. However, Prudential will use cc r :c Crcrs -I: I r:: c,,.. .. ,, _,cr re:e: n. , ;,rc,: r; ,. cccccr ng ..,c , in Prudential's standard format, to the Plan Sponsor or to a successor recordkeeper. Should the termination of Services be concurrent with a termination of the Plan, Prudential will use reasonable efforts to pay or roll over Participant accounts pursuant to the Plan Sponsor's and, as appropriate, the Participants' instructions. Prudential reserves the right to suspend some or all types of Plan transactions prior to transfer or payout for a period reasonably necessary to reconcile all account, expense, and asset totals. 3. Related Terms and Conditions. Plan Sponsor agrees to the terms and conditions of a Participant's or other party's use of Prudential's electronic service systems, including Interactive Voice Response (IVR), Internet, or call center, provided Prudential notifies the user of such medium of the terms of its use. Prudential agrees that the terms and conditions shall be reasonable and not inconsistent with other provisions of this Agreement and Plan terms provided by authorized Plan representatives. 4. Amendment. The Agreement may be amended by mutual agreement at any time in writing. Agreement by the Plan Sponsor to an amendment that would impact plans of a similar class on Prudential's recordkeeping system may be presumed if Prudential communicates the amendment to the Plan Sponsor at least ninety (90) days in advance of the effective date of the change in conformance with the notice section of this Agreement, indicates its intention to presume agreement to the amendment absent a response, and Prudential receives no response within a stated period or, if none is stated, by the time the change is to be implemented. Prudential's fees are subject to annual review by Prudential and may be changed effective after ninety (90) days written notice to the Plan Sponsor. The fees will not be changed within the first sixty (60) months following the Agreement's Effective Date, nor will it be changed more frequently than once in any twelve (12) month period except by written agreement between Prudential and the Plan Sponsor. Prudential reserves the right to amend the fees upon sixty (60) days written notice in the event of a material change to the Plan, a difference in the expected versus actual conversion assets received, a material reorganization or other extraordinary event, or from significant decline in assets, contributions or number of participants. E. Indemnification 1. Error Correction: Indemnification of Plan and Plan Soonsor. Prudential, subject to the terms of this Agreement, agrees to pay costs associated with the correction of Prudential's administrative errors or omissions in the performance of Services listed in Exhibit A hereunder to the extent of its negligence or willful misconduct, provided that the Plan Sponsor agrees to a reasonable error correction method within twenty (20) business days of receiving written notice of the proposed correction method. 25D-8 v Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company In addition, Prudential agrees to indemnify the Plan from every loss, claim, demand or suit arising from any specific act of negligence or willful misconduct by Prudential in the performance of Services listed in Exhibit A hereunder provided that any Participant or beneficiary who claims to have been affected thereby makes a timely and proper claim under the benefit claims procedure of the Plan, if applicable, and provided that any such claim is made by the Plan Sponsor, Participant or beneficiary (a) sixty (60) days from the mailing of a trade confirmation, account statement, or any other document, from which the error can be discovered, but in any event within (b) one year from the transaction related to the purported error. Prudential, at its own expense, will defend, or at its option settle, any formal demand or court proceeding that may be brought against the Plan, on any matter covered by this indemnification, and will pay or reimburse the Plan for any judgment, settlement, and any reasonable expenses of the proceeding that may be rendered against it with respect to any such claim or demand, provided that the Plan Sponsor notifies Prudential in writing within twenty (20) business days of receipt of such claim or demand and cooperates with Prudential in its defense. Prudential's liability will be limited to actual damages and reasonable out-of-pocket legal fees and 2. Indemnification of Prudential. Plan Sponsor agrees to indemnify Prudential from every loss, claim, demand or suit arising out of any action Prudential takes or omission Prudential allows under the specific or assumed direction of the Plan Sponsor, to the extent that such loss, claim, demand or suit is not the direct result of Prudential's own negligence or willful misconduct, provided that Prudential notifies the Plan Sponsor in writing within twenty (20) business days of receipt of such claim or demand. Prudential may, after notice to the Plan Sponsor, defend, or at its option settle, any formal demand or court proceeding that may be asserted against it for any matter covered by this indemnification. Plan Sponsor will, upon presentation of a reasonable accounting, pay or reimburse Prudential for any judgment, settlement amount, and expenses of the proceeding, including reasonable legal fees. Plan Sponsor may request to take over defense of a claim or court proceeding, and Prudential will have no further liability for such matter except as specifically accepted in writing by a Prudential corporate officer or legal counsel. In addition, Plan Sponsor will, upon presentation of a reasonable accounting, pay or reimburse Prudential for expenses, including but not limited to labor and production costs, related to Prudential's response to subpoenas or other requests for documents issued by regulatory agencies, courts, or other authorized parties in connection with Prudential's provision of Services under this Agreement. F. Intellectual Property; Nondisclosure; Security Intellectual Property. Nothing contained in this Agreement shall confer to Plan Sponsor any property rights, proprietary interest, copyright or license in Prudential assets or technology, including, without limitation, the software, written materials, screen formats, or report formats used or developed to provide the Services. Plan Sponsor acknowledges that such assets and technology constitute copyrighted material, trade secrets or proprietary information of substantial value to Prudential. Plan Sponsor agrees it shall treat the foregoing as proprietary to Prudential and that it shall not divulge any such proprietary information to any person or organization except as expressly permitted hereunder or as required by law. Notwithstanding this provision, all Plan data, Participant data, Plan Sponsor information and any other materials pertaining to the Plan provided to Prudential shall remain the Plan Sponsor's property. 2. Non -disclosure. The parties understand that the performance of Services by Prudential will necessitate the sharing of information, including that which relates to the Plan Sponsor, the Plan, Participants, corporate -owned life insurance policies (if applicable), the format or content of Prudential's reports and internet website, and the processes used by Prudential to perform its Services, all of which is considered by the disclosing party to be confidential. Each party agrees not to use any confidential information received from the other party or obtained in performance of this Agreement, whether in writing or, orally, for any purpose except in connection with the Plan or in 2501-9 ww Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company furtherance of the Services. The parties hereto shall not include In any transmission of information any proprietary or confidential data or information ("Proprietary Information") without clearly notifying the receiving party of the proprietary or confidential nature of such communication. The receiving party shall make reasonable efforts, to the extent allowed by law, to keep such Proprietary Information confidential, and not to disclose such Proprietary Information to any third party without the prior written consent of the disclosing party, except as otherwise permitted under this Agreement. Such Proprietary Information shall be protected by the receiving party by utilizing the same or similar security procedures as are used by the receiving party in protecting its own trade secrets and confidential or proprietary information. The parties' obligation of nondisclosure shall terminate upon the completion of any record retention requirements. 3. Exceptions to Non -disclosure. Notwithstanding any provision in this Agreement to the contrary, or of any confidential or proprietary markings placed on any transmission of information, Prudential shall not be prohibited from disclosing Proprietary Information (i) to officers or employees of Plan Sponsor .. - he re-ulrcr! for �am;..�rb^rl,P j : r,: C"n^ .nh�Ca rn "'C Dlnn M% 1n nry Participant's survivors or designated agent to the extent such information pertains to such Participant, (Ili) where in furtherance of the Services under this Agreement, including without limitation in accordance with Section 8(4) above, (iv) in accordance with Section G(8) below, or (v) as required by court order, subpoena, document request or other legal process. The obligation to maintain the confidentiality of Proprietary Information shall not apply to: (t) Proprietary Information that was in the public domain prior to the receiving party's receipt or has subsequently become part of the public domain through no action of the receiving party, (ii) Proprietary Information that was in the receiving party's possession prior to its receipt and was not acquired directly or indirectly from the other party, (iii) Proprietary Information that was received from a third party which the receiving party reasonably believes has no obligation of confidentiality, or (iv) as required by law. 4. Security. Prudential will employ all commercially reasonable measures to ensure the confidentiality, security, and privacy of information obtained by Prudential concerning the Plan Sponsor, the Plan Sponsor's employees, the Plan, and Plan participants and beneficiaries. Without limiting the generality of the foregoing, Prudential represents and warrants that it is, and will remain compliant with applicable laws and/or regulations with respect to the privacy and security of customer information, and that it has implemented and currently maintains an effective information security program designed to protect Prudential's customer information, which program includes administrative, technical, and physical safeguards that are designed: a) to insure the security and confidentiality of customer information; b) to protect against any anticipated threats or hazards to the security or integrity of such customer information; and c) to protect against unauthorized access to or use of customer information which could result in substantial harm or inconvenience to Prudential's customers. G. Miscellaneous 1. Duration. This Agreement will continue in effect for a period of three (3) years from the effective date of this Agreement, unless sooner terminated in accordance with the provisions of this Agreement. In addition, the Plan Sponsor may extend this Agreement for an additional two 2 year period. Until terminated the Agreement shall bind all successors in interest of the parties, but cannot be transferred or assigned to unaffiliated third parties without the consent of both the Plan Sponsor and Prudential. 2. Entire Agreement. Unless otherwise provided herein, this Agreement, including the Exhibits, attached hereto and the Administrative Procedures contains the entire Agreement among the parties 25D-10 Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company with respect to the subject matter described. Plan Sponsor acknowledges a copy of the current Administrative Procedures was provided in the Implementation Workbook. 3. Passwords. In connection with electronic access to accounts and transactions, Participants will be assigned (and the Participant may then change) a unique number, code or other sequence (a 'Password'). The Plan Sponsor acknowledges that Prudential will hold each Participant responsible for the use and protection of the Password, and for monitoring their accounts. Plan Sponsor agrees Prudential is not responsible for direct or indirect losses or damages arising from the unauthorized use of a Password occurring before it is notified that a Password is compromised, unless such unauthorized use is the result of Prudential's negligence or willful misconduct. 4. Notice of Errors. The Plan Sponsor agrees that all information supplied to the Plan Sponsor and Participant will be deemed correct if notice of any error or discrepancy is not given to Prudential by the Participant or the Plan Sponsor as soon as reasonably possible following identification of the error or discrepancy, provided that Participants must notify Prudential of errors or discrepancies in a quarterly statement no later than the time period specified in such statement. 5. Severability. If any term or provision of this Agreement or its application to any person or circumstances will, to any extent, be invalid or unenforceable, the remainder of this Agreement, or the application of such term or provision to persons or circumstances other than those as to which it is held invalid or unenforceable, will not be affected. Each term and provision of this Agreement will be valid and enforceable to the fullest extent permitted by law. 6. Governing Law. This Agreement shall be governed by and construed in accordance with the laws of California applicable to agreements made and to be performed entirely within California, except the choice of law rules. 7. Notice Notices required under this Agreement shall be in writing and shall be addressed to the appropriate party at the address set forth on the signature page or such other address as either party may designate in writing to the other. All notices will be deemed to have been given three (3) days after mailing in the U.S. mail, or immediately upon delivery in any form. The notice period may be waived by the party entitled to the notice. 8. Forces Beyond Prudential's Control. Prudential will take commercially reasonable steps to prevent and to recover from disruptive events that are beyond its control. However, Prudential shall not be liable for any default or delay in the performance of Services if the default or delay is primarily caused, directly or indirectly, by a force or party beyond the reasonable control of Prudential, including (but not limited to): (a) Fire, flood, elements of nature or other acts of God; (b) Any outbreak or escalation of hostilities, war, riots or civil disorders in any country; (c) Any act or omission of the other party or any governmental authority; (d) Nonperformance of an unaffiliated third party; or (e) Failures or fluctuations in telecommunications, power supply, mechanical difficulties with information storage and retrieval systems, or other equipment. 9. Writing and Sionature: Electronic Transactions. Unless otherwise explicitly required by law, any requirement for a writing (including an enrollment, exchange or distribution request, instruction, form, administrative notices, or agreement) or a signature in this Agreement, or in the performance of Services under it (collectively referred to as "Communications"), may be rendered in any form (including electronic means) that: (i) can reasonably be expected to be accessible to the parties needing to send or receive it, (ii) is convertible into an accurate physical record of the Communication, and (iii) where appropriate, is designed to test or confirm the identity or authority of the Communication's sender. Prudential reserves the right to specify the form in which Communications re)a(ing ty,JPIBn P.perations are made, including limiting them to electronic means, 25D-11 mi Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company and will notify the Plan Sponsor and, if necessary, any affected Participants of the addresses, telephone numbers, Internet addresses, etc. which may be used for these contacts. If the Plan uses an individually designed non -Prudential plan document, the Plan Sponsor is responsible for assuring that the Plan document does not bar electronic or other non-traditional means of recording and authenticating actions in connection with Plan operations. 10. Prudential's E -Delivery Program at the Workolace. If the Plan Sponsor elects Prudential's E -Delivery at the Workplace Program, the Plan Sponsor directs and authorizes Prudential to electronically deliver certain documents to Participants, including Participant account statements, and may be expanded over time to include other documents upon notification by Prudential. Plan Sponsor acknowledges and represents as follows: a. For each Participant for whom an e-mail address is provided to Prudential by the Plan ., 1 .U- rL„-..,: �1, 4 C � �..iru�,. :;=_ :hC �C C"CC;Y: dy .,CGC.. �0.,.. n•G^„L fCL�'G� electronic form at any location where the Participant is reasonably expected to perform his or her duties as an employee, and (2) the Participant's access to the employers electronic system is an integral part of his/her duties; b. The Plan Sponsor will: (1) provide Prudential with a current and accurate list of email addresses of Participants eligible to receive electronic delivery in accordance with paragraph (a), and (2) notify Prudential within seven (7) days after any Participant described in paragraph (a) above terminates employment or otherwise no longer satisfies the requirements of paragraph (a) above. Prudential acknowledges and represents as follows: a. Prudential has electronic delivery protocols for the handling of undelivered or otherwise invalid e-mail addresses; b. Participants will be assigned a unique number, code or other sequence (a "Password") to protect the confidentiality of the Participant's personal information in accordance with this Agreement; Upon the Participant's request, Prudential will deliver to the participant a paper version of the electronic document at no charge. Prudential may terminate this program at any time and neither party shall have any further obligations. Upon termination of this program, documents will be delivered to Participants in paper format and mailed to the US Mail address that Prudential has on file for the Participant unless the applicable Participant has separately and independently consented to electronic delivery. 11. ,Other Services. The Plan Sponsor agrees that from time to time Prudential and/or its affiliated companies may provide both current and former employees of the Plan Sponsor, and Participants in the Pian, with information on other products and services provided by Prudential. However, Prudential shall not divulge any information regarding the current or former employees of the Plan Sponsor, or Participants in the Plan, to any person outside the employ of Prudential without the consent of the Plan Sponsor or unless legally required to do so. Prudential and/or its affiliates may provide additional services to the Plan as may be separately agreed upon with the Plan Sponsor. 12. Independence of Plan Signatory. Plan Sponsor confirms that the person signing the Agreement on behalf of the Plan (the "signer") is "independent," within the meaning of the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), such that, to the best of its knowledge, the `signer will not receive commissions or other consideration directly or indirectly from Prudet'itital11:11i�u" k" 25D-12 (6 Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company Affiliates, from the Selling Broker or its Affiliates or from the Registered Representative or from Relatives of the signatory. For purposes of this section, an "Affiliate" of an entity is (i) a partner, director, officer or employee of such entity or (ii) another entity controlled by or under common control with such entity and a "Relative" of an individual is the individual's ancestor, spouse, brother, sister, spouse of a brother or sister, direct descendent (including adopted persons) or spouse of a direct descendent. 13. Market Timing/Excessive Trading Monitoring Program. Plan Sponsor agrees that Participant transactions will be subject to Prudential's Market Timing/Excessive Trading Program, as described in the Disclosures section of the Implementation Workbook. 14. Records Retention. After the termination of the Agreement, Prudential will retain all books and records in its possession, whether in hard copy or in an electronic format, relating to the Plan for such period as required by law and its Records Management Program. Prudential will cooperate in = r:ar, .1poni,.. copies of materials in its possession upon request and at the Plan Sponsor's expense. 15. Audits. The Plan Sponsor shall have the right to conduct an audit of Prudential's performance of the Services, including through the inspection of Prudential's records and information maintained in connection therewith, and Prudential agrees to reasonably cooperate with such audit; provided that (i) Prudential receive written notice setting forth the anticipated objectives, scope, procedures and information and records required relating to the audit no less than thirty (30) days, (ii) such audits may not be conducted more frequently than once per Plan Year without Prudential's written consent, and (iii) the Plan Sponsor will reimburse Prudential for the expenses and costs it incurs in providing such cooperation. Prudential agrees to reasonably cooperate with any audit relating to the Plan conducted by applicable regulatory agencies. 16. Insurance. Prudential shall at all times during the term of this Agreement, at its own cost and expense, carry and maintain commercially reasonable insurance coverage, including the insurance policies listed below. • Worker's Compensation and Employer's Liability insurance, with statutory limits for workers' compensation and Employer's Liability limits of $1,000,000 per accident. • Commercial General Liability insurance, insuring against claims for bodily injury, property damage, completed operations and contractual liability with a limit of $1,000,000 per occurrence and $2,000,000 in the aggregate. • Automobile Liability insurance covering all owned, non -owned, hired and leased vehicles used in the performance of this Agreement with a combined single limit of $1,000,000. • Casualty Umbrella or Excess Liability follow -form insurance in the amount of $5,000,000. • Professional Liability or Errors & Omissions insurance with limits of at least $5,000,000 each claim or wrongful act with a $250,000,000 deductible. • Fidelity Bond or Comprehensive Crime insurance covering employee dishonesty with limits of at least $5,000,000 each claim with a $250,000,000 deductible. • Cyber Risk or Privacy Liability insurance with limits of at least $5,000,000 each claim or wrongful act with a $250,000,000 deductible. Prudential will be solely responsible to pay and determine the deductibles on these insurance policies, which will be;issued-by insurance carriers with an A.M. Best rating of A- or better. In the 25D-13 WV Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company event that any of the above-described insurance policies are written on a claims -made basis, then such policy or policies shall be maintained during the entire period of the Agreement and for a period of two (2) years following the termination or expiration of the Agreement. Prudential will provide reasonable notice of any material adverse change or cancellation of the above-described insurance coverage. Authorizing Plan Fiduciary shall be included as an additional insured on the above -referenced policies. Certificates of insurance matching the terms of this § 9 will be provided upon Authorizing Plan Fiduciary's reasonable written request. This § 9 does not limit or expand Prudential's indemnification obligations. 10 25D-14 Prudential NEW Services Agreement Provided by Prudential Retirement Insurance and Annuity Company The persons signing below affirm that they are authorized to act on behalf of the parties to this Agreement and that the parties agree to be bound by the terms of this Agreement. CITY OF SANTA ANA: $ea Artarha.l Cionao_ t,irr Page Name Authorized Signature Title PRUDENTIAL RETIREMENT INSURANCE AND ANNUITY COMPANY: Name Authorized Signature Date Signed Date Signed Address for Notice: Address for Notice: City of Santa An Prudential Retirement 20 Civic Center Plaza 30 Scranton Office Park Santa Ana. CA 92701 Scranton, PA 18507 Attention: Human Resources Attention: Key Accounts a.=.S�'V N� LIe4n 25D-15 11 ATTEST: MARIA HUIZAR Clerk of the Council CITY OF SANTA ANA RAUL GODINEZ, II City Manager APPROVED AS TO FORM: z)UMA t(. l,Ai<'VALHU City Attorney ByjG2l-►Iw k • �c 1J1 Laura A. Rossini Senior Assistant City Attorney FOR APPROVAL: FRANCISCO GUTIERREZ Executive Director of Finance and Management Agency 25D-16 mi Prudential Section 1. EXHIBIT A CORE SERVICES Services Agreement Provided by Prudential Retirement Insurance and Annuity Company The Services listed below are available to your Plan and will be administered in accordance with the Administrative Procedures and, if applicable, the Plan Sponsor elections set forth below. Some Services are dependent upon receipt of all required data in a manner acceptable to Prudential. A. ADMINISTRATIVE & RECORDKEEPING SUPPORT TRANSITION MANAGEMENT • Transition Manager assigned to provide daily support to facilitate the transition of your Plan to Prudential • Participant communications, featuring company name, logo and market -specific images, to inform of transition related information and events. Preferred method of delivery is E -Delivery to the Plan Sponsor, however, home mailing of material to Plan Participants is available. • Mapping of existing Plan document to Prudential's specimen document. • PLAN -SPECIFIC TRANSITION WEB PAGE to keep employees Informed of Important information regarding the conversion of your Plan to Prudential. RELATIONSHIP MANAGEMENT whereby a Prudential associate will be assigned to provide ongoing support following the transition of your Plan to Prudential. MAINTENANCE OF PLAN RECORDS AND TRANSACTION PROCESSING: Prudential will provide the following services, if applicable, to your Plan: • Ongoing maintenance of Plan and Participant accounts and records. • Contribution processing and pricing (e.g. employee and employer contributions, and loan repayments) via Prudential's standard automated applications. • Automated Clearing House contribution funding, upon receiving a contribution file in good order, Prudential will debit the designated account for the required amount to fund the contribution. • Distribution Transaction Processing (see Plan Sponsor Elections below): Fully automated transactions: Paperless (i.e. web or IVR initiated) participant transactions approved by Prudential's systems per the established plan rules and data received from the Plan Sponsor. Sponsor Approved transactions: Paperless (i.e. web or IVR initiated) participant transactions approved by the Plan Sponsor via automated methods. • Direct Service Option (DSO). If agreed to by the Plan Sponsor, Prudential will provide administrative services with respect to Participants no longer employed by the Plan Sponsor who elect or are deemed to elect to retain their account balances in the Plan. By electing this service the Sponsor agrees that Prudential may charge expenses associated with distribution and administration (as applicable) directly to each terminated Participant's account • Loan Services including loan rate monitoring (see Plan Sponsor Elections below), loan default notification services, refinancing, loan services for terminated Participants no longer submitting loan repayments via automated remittance methods. If agreed to by the Plan Sponsor, Prudential will accept loan repayments from Participants via the Automated Clearing House ("ACH') network. • Participant address changes (see Plan Sponsor Elections below). • Collection of participant deferral rate changes (see Plan Sponsor Elections below). • Online beneficiary designation and maintenance. 12 2501-17 A, Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company • Eligibility determination and vesting calculations for Plans with immediate, elapsed time, anniversary with hours counting or anniversary with hours counting and change to plan year eligibility methods. A Plan entry notification report will be posted to the Plan Sponsor Website prior to a newly eligible employee's earliest plan entry date. (See Plan Sponsor Elections below). • Prudential will provide standard Plan information materials to participants and will accept and record resulting participant enrollment information. If permitted by the Plan, Prudential will accept and record enrollment information prior to their eligibility date. • Prudential will verify that requested rollovers into the Plan can be accepted according to the plan provisions and applicable law. • Automated cashouls of small balance accounts upon separation from service, either via direct rollover or check to Participant. • Required Minimum Distributions (RMD) support, includes annual Sponsor report identifying Participants attaining age 70 %, notification to affected Participants, processing of resulting transactions, and support of a default process for non respondent Participants. TRUSTEE SERVICES, Prudential Bank & Trust Services, directed trustee services as defined in the separately executed trust agreement. QUARTERLY PARTICIPANT EDUCATION PROGRAM, a communication & education strategy supporting transition and the essential elements of retirement planning (i.e. enrollment, increasing participation, asset allocation, withdrawal strategy and consolidation). Delivery methods include direct mail campaigns, webinars, podcasts and e -articles. PLAN SPONSOR WEBSITE (PSW), with unlimited access to: • Plan Information • Participant Information • Investment Information and Performance • Library of easy -to -access reports • Resource center with pension -related information and links to related websites PLAN REPORTING, including: • Annual Plan Summary including information on the overall retirement market environment, a "scorecard" that measures results achieved in the past year, current initiatives underway, and considerations for future business planning. • Semi-annual Plan Summary -Enhanced, which contains statistics on Plan demographics, asset allocation, Participant behavior and results of implementation of key Plan features/products. • Required Disclosure Information. • GASB 40 reporting for Governmental clients, which is a financial report that details the key financial risks of funds within the plan, including interest rate risk, credit risk, and foreign currency risk. • Plan Sponsor Website Reporting • Investment Performance Grids: Plan specific performance report, provided on a quarterly basis, that details performance of client funds next to all funds on platform. STANDARD FEE PROCESSING via quarterly invoices to the Plan Sponsor, quarterly per Participant deductions and/or ongoing deduction of transaction based Participant fees. Any applicable per Participant fees are calculated on a per capita basis and applied to all Participants with a balance at the time of the fee processing. PARTICIPANT ENGAGEMENT SUPPORT: • Toll-free phone access to Participant phone representatives, for ongoing account information and retirement planning support. • Multi-lingual phone services & Telecommunications Device for the Deaf (TDD) 13 25D-18 Mw Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company • Interactive Voice Response (IVR) System • Participant Website, including a tool to monitor progress toward retirement readiness. • Online transaction processing, as allowed by the Plan Sponsor • Online beneficiary designation and maintenance • Enrollment materials, which may be delivered via hard -copy bulk -shipment or electronically delivered to Participants (through the electronic -enrollment program, if selected). • On-site retirement & financial literacy meetings • Education campaigns, webinars, online articles • Unlimited access to self -serve tools, including an online retirement income calculator, retirement education & planning tools and articles. • Quarterly Participant account statements which summarize Participant account information, Participant transaction activity, and Plan investment performance. • "Off the Shelf' communication pieces are available upon request (bulk shipped to the plan sponsor.) GOVERNMENT TAX WITHHOLDING AND REPORTING (e.g. Form 945, Form 1099-R) LEGISLATIVE AND REGULATORY SUPPORT to help you stay informed of changes, including: • Communications and articles describing changes impacting retirement plans. • Online access to Plan compliance tools, pension information & links to related -topic sites. • A checklist to support compliance with Plan reporting and disclosure requirements. • Plan Audit Support, including Prudential Retirement SSAE16, Auditor's Corner, Plan & Participant Information self service requests, as well as the following other requests: loan & disbursement forms and check copies. Plan Audit Support is available for a two year period (past two plans years are Included on the web only). Audits for plan years outside this range may be subject to Additional Audit Support fees. PLAN DESIGN AND DOCUMENT SUPPORT including: • General support on inquiries related to plan design/definitions/interpretations for Prudential's specimen documents. • Plan amendments and/or restatements, based upon either regulatory or legislative changes or changes initiated by Prudential for Plans using Prudential's specimen document. 14 2501-19 Woo Prudential B. INVESTMENT ADMINISTRATION Prudential will provide the following deliverables. Services Agreement Provided by Prudential Retirement Insurance and Annuity Company STANDARD INVESTMENT POLICY STATEMENT (IPS), a template which outlines the underlying philosophies and processes for the selection, monitoring and evaluation of the investment options utilized by the Plan. INVESTMENT PERFORMANCE INFORMATION, which includes fund prices, fund performance and benchmarking data. INVESTMENT FACT SHEET INFORMATION available through the plan sponsor and participant websites. QUARTERLY INVESTMENT MONITOR, a document which includes a breakdown of Plan assets by investment, investment performance, market commentary, and additional investment considerations. W 25D-20 Services Agreement MW Prudential Provided by Prudential Retirement Insurance and Annuity Company Section 2. ELECTION OF ENHANCED SERVICES The following optional Services have been elected by the Plan Sponsor. The Services will be administered in accordance with the Administrative Procedures. Some Services are dependent upon receipt of all required data in a manner acceptable to Prudential. A. ADMINISTRATIVE & RECORDKEEPING SUPPORT THE INDUSTRY TREND REPORT, which compares industry data, including statistics on various plan features, services and Participant behaviors to your Plan. AD-HOC REPORTING, to provide plan data and/or analysis through a specialized report, exhibit, or data table that is not available through other plan administrative reports. PARTICIPANT SUPPORT: AGREED UPON NUMBER OF ADDITIONAL INSTRUCTOR -LED PARTICIPANT EDUCATION WEBINARS. CUSTOM COMMUNICATIONS which includes support by a communications strategist who will develop and implement a Plan -specific communication strategy. Additional services may include onsite meetings, custom websites or custom campaigns. Additional costs will apply to the actual services and tools identified in the custom strategy. PLAN DOCUMENT SERVICES: DISCRETIONARY PLAN AMENDMENTS AND RESTATEMENTS, for Plan Sponsor- initiated/discretionary changes using Prudential's specimen document. CONSULTING SERVICES, Plan -specific guidance and consultation on a series of complex topics, including but not limited to merger & acquisition, Plan design & analysis, DOL/IRS correction programs, fiduciary responsibilities and 404(c) compliance. Projects requiring a formal proposal will include a statement of work and estimate of the charges, delivered prior to the commencement of the work. B. INVESTMENT ADMINISTRATION INVESTMENT COMMITTEE MEETING SUPPORT delivered via phone. W 25D-21 1 Services Agreement T PrudentialProvided by Prudential Retirement Insurance and Annuity Company PLAN SPONSOR ELECTIONS (Eff. 10/1/2018) The Plan Sponsor has elected the following services, options or frequencies for administration of the Services noted. PRUDENTIAL'S E -DELIVERY PROGRAM AT THE WORKPLACE Yes ® No ❑ DISTRIBUTION TRANSACTION PROCESSING ®i ui�j uu.�ii 4l utC.J aul,Jui.l,iuiiv ®Sponsor Approved transactions PARTICIPANT TRANSACTIONS via non-core initiation and approval methods. Transactions will be reviewed and approved based on the agreed upon criteria in the Administrative Procedures and the Plan Sponsor Elections above. Transaction Initiation A roval In -Service Withdrawals Paperless Prudential Event Distributions (i.e. termination, retirement disability) Paperless Prudential Participant Loans Paperless Prudential Qualified Domestic Relations Orders Paper only Prudential Distributions Due to Death Paper only Prudential AUTOMATIC ENROLLMENT CONTRIBUTION ACCELERATOR ® Opt In ❑ Opt Out INVOLUNTARY DISTRIBUTIONS LOAN RATE MONITORING — LOAN INTEREST RATES Per the Plan's loan policy Prudential will apply and monitor the interest rates noted below: General Purpose Loans: Prime + 2 % Primary Residence Loans: Prime + 2 % LOAN REPAYMENTS VIA AUTOMATED CLEARING HOUSE (ACH) Active Participants Plan Sponsor authorizes Prudential to establish loan repayments by Participants through the Automated Clearing House network through a separate agreement with, and instructions from, each applicable Plan Participant. ❑ ACH or Coupon (only allowed if Payroll Deduction is NOT offered) ❑ ACH Only (only allowed if Payroll Deduction is NOT offered) 17 25D-22 Services Agreement Prudential Provided by Prudential Retirement Insurance and Annuity Company Terminated Participants Plan Sponsor authorizes Prudential to establish loan repayments by Participants through the Automated Clearing House network through a separate agreement with, and instructions from, each applicable Plan Participant. ❑ Convert to ACH ❑ Convert to ACH or Coupon Note: For either active or terminated participants, loan conversion from Payroll Deduction or ACH to Coupon could result in a participant fee. LEAVE OF ABSENCE - LOAN SUSPENSIONS AND REAMORTIZATIONS ❑ The Plan will allow the original term of the loan to be extended for the period of leave if the original In n n�m In Ince fl��n fvo ,pnrs ❑ The Plan will not allow the original term of the loan to be extended for the period of leave if the original loan tens is less than five years. PARTICIPANT ADDRESS CHANGES will be accepted from: ❑ Plan Sponsor and/or ❑ terminated Participants and beneficiaries PARTICIPANT DEFERRAL RATE CHANGES Frequency at which Prudential will report changes Prudential receives from Participants to the Plan Sponsor: ❑ Daily ❑ Weekly ❑ Bi -Weekly ❑ Information available on Plan Sponsor website ELIGIBILITY — PLAN ENTRY Prudential will post a plan entry notification report to the Plan Sponsor Website, as follows: ❑ 30 days prior to the employee's earliest plan entry date ❑ 45 days prior to the employee's earliest plan entry date ❑ 60 days prior to the employee's earliest plan entry date ❑ Report not provided 18 25D-23 Services Agreement Wlb Prudential Provided by Prudential Retirement Insurance and Annuity Company EXHIBIT B Confidentiality, Privacy, and Information Security A. Personal Information "Personal Information" means information provided by or on behalf of the Plan, Plan Sponsor or Plan Participants, or their agents to Prudential or its agents in the course of Prudential's performance of the Services under this Agreement that: a) identifies an individual (by name, signature, address, telephone number or other unique identifier), or b) can be used to identify or authenticate an individual. Personal Information includes (i) an individual's government -issued identification number (including social security number, drivers license number or stale -issued identified number); and (ii) financial account number in combination with any required security code, access code, personal identification number or password, that would permit access to an individual's financial account. B. Confidentiality Prudential agrees to keep and maintain all Personal Information in strict confidence, using an appropriate degree of care to avoid unauthorized use or disclosure. Prudential may disclose Personal Information to its employees (individually an "Employee" and collectively, 'Employees") having a need to know this information in connection with the performance of the Services for Plan Sponsor. Prudential may also disclose Personal Information to its affiliates and its subcontractors having a need to know this information in connection with the performance of Services for Plan Sponsor. Prudential shall instruct all Employees, affiliates and subcontractors of their obligations under this Agreement. If Prudential receives any order, demand, warrant, or any other document requesting or purporting to compel the production of Personal Information under applicable law (including, for example, by oral questions, interrogatories, requests for information or documents in legal proceedings, subpoenas, civil Investigative demands or other similar processes), Prudential shall notify Plan Sponsor in writing (except to the extent otherwise prohibited by applicable law). C. Destruction and Retention of Personal Information Upon the earlier of (i) the completion of an engagement or termination of this Agreement; (ii) a determination that it has no need for Personal Information; or (iii) at any time Plan Sponsor requests, Prudential shall dispose of all records, electronic or otherwise regarding or including any Personal Information that Prudential may then possess or control by destroying them pursuant to Prudential's written policy governing records destruction. Notwithstanding the foregoing, Prudential will not be obligated to destroy Personal Information (i) it is required by law or regulation to retain, but then only for the time period required, (ii) is commingled with other information or documents of Prudential if it would pose an administrative burden to destroy such Personal Information, or (iii) if the Personal Information is contained in an archived computer system or back-up in accordance with its standard security policy. Such Personal Information will be retained in accordance with the requirements of this Agreement. 19 25D-24 Prudential D. Information Security Program Services Agreement Provided by Prudential Retirement Insurance and Annuity Company Prudential states that (i) its treatment of Personal Information is in compliance with applicable laws and regulations with respect to privacy and data security, and (ii) it has implemented and currently maintains an effective written information security program including administrative, technical, and physical safeguards and other security measures necessary to (a) ensure the security and personality of Personal Information; (b) protect against any foreseeable threats or hazards to the security or integrity of Personal Information; and (c) protect against unauthorized access to, destruction, modification, disclosure or use of Personal Information that could result in substantial harm or inconvenience to Plan Sponsor, or to any person who may be identified by Personal Information. Without limiting Prudential's obligations under this exhibit, Prudential shall protect and maintain the confidentiality and security of any Personal Information provided to or created by Prudential related to the Services by or on behalf of Plan Sponsor in the manner provided for under, and otherwise in compliance with any applicable domestic laws, regulations, and rules related to the collection, storage, handling, processing, and b� ren• n� Pn.r J.n�l Ln Fn•m Blinn ,CI[.1{nn inf�.m �lir.n rCcn^. n.rJinr in�n•irV,,nlr E. Remediation Prudential shall notify Plan Sponsor, without unreasonable delay, upon confirming that an unauthorized access or disclosure, unauthorized, unlawful or accidental loss, misuse, destruction, acquisition of, or damage to Personal Information while under the responsibility or in the possession of Prudential (a "Security Incident) has occurred. Thereafter, Prudential shall; a) promptly furnish to Plan Sponsor details of the Security Incident; b) conduct an investigation into the Security Incident; c) take appropriate action to prevent a recurrence of any Security Incident; d) determine whether notice is to be provided to any individuals, regulators, consumer reporting agencies, or others under applicable law or regulation; e) draft the contents of each such notice; and f) offer remediation to affected persons consisting of two years of credit monitoring services if such Security Incident poses a significant risk of identity theft and is required by law or regulation. Any such notice or remediation shall be at Prudential's sole cost and expense. 20 2501-25 MW Prudential EXHIBIT C Plan Administrative Expenses Services Agreement Provided by Prudential Retirement Insurance and Annuity Company Prudential agrees to make payments ("Allowance") to or on behalf of the Plan in order to pay its reasonable and actually incurred Plan administration expenses. Prudential will make payment to the Plan as more fully provided below: • Source of Payment. The source of funds for the payment is corporate assets of Prudential and/or its subsidiaries and affiliates. The Plan Sponsor acknowledges that Prudential is the owner of funds used for the payment until Prudential transfers such funds to the Plan Trust. • Amount. Allowance will be paid to the Plan in periodic installments of an annual amount as set forth below: • Flat Dollar Amount. $5,000 for the plan year in which Prudential commenced services to the Plan and $5,000 for each calendar year thereafter. The Allowance will be paid in quarterly installments. Payments other than annual will be calculated by dividing the annual amount by4. • Additional Amount. Allowance may be made available to the Plan as a result of service shortfalls as described in Exhibit D of this Agreement. • Plan Expense Account. Prudential will establish an account for the Plan Trust on Prudential's recordkeeping system. Prudential will deposit payments of the Allowance into this account at the frequency defined above and invest them in a stable value investment under the Plan, unless another investment option is selected by the Plan Sponsor until such time that the Plan Sponsor provides direction to Prudential regarding the disposition or re- investment of these funds. • Reporting. Prudential will provide periodic reports to the Plan Sponsor that show payments by Prudential to the Plan Trust under this arrangement. • Amendment of Arrangement. This payment arrangement may be amended at any time in writing. Agreement by the Plan Sponsor to an amendment may be presumed if Prudential communicates the amendment to the Plan Sponsor in advance of the effective date of the change, indicates its intention to presume agreement to the amendment absent a response, and Prudential receives no response within a stated period or, if none is stated, by the time the change is to be implemented. In particular (and not by way of limitation), Prudential reserves the right to amend this arrangement in the event of a material change to the Plan or a difference in the expected versus actual conversion assets. • Termination of Arrangement. Each party may terminate this payment arrangement for any reason upon thirty (30) days prior written notice to the other. In particular (and not by way of limitation), Prudential reserves the right to terminate this arrangement in the event of a material change to the Plan or a difference in the expected versus actual conversion assets, or upon Prudential's conclusion that payments violate applicable law. Generally, allowances are made available upon conclusion of the payment period. Plan Sponsor agrees, represents and warrants to Prudential: 21 2501-26 Prudential Services Agreement Provided by Prudential Retirement Insurance and Annuity Company • All instructions received pursuant to this provision will be submitted by persons authorized to act on behalf of the Plan and Prudential may rely upon those instructions as being genuine and duly authorized; • The Plan document and any applicable Trust documents permit the Plan to make payment of administrative expenses from Plan assets; • This Allowance is permissible under both the Plan documents and any laws applicable to the Plan; • All amounts paid pursuant to these provisions will be used solely for Plan administrative expenses that are reasonable and necessary to the Plan; • Plan Sponsor will indemnify and hold Prudential harmless to the extent that there is a breach iii oily ui UlG ItNi wcllla'u UI1J WlllaillcU IlCltitli, JVil Rlri uauJw h IJUt)i,llal iti bul;w aiiy expense or damage as a result; and • Plan Sponsor has discussed this arrangement with its legal counsel to the extent it deems appropriate. 22 25D-27 vArm Prudential EXHIBIT D Performance Standards Services Agreement Provided by Prudential Retirement Insurance and Annuity Company Prudential and the Plan Sponsor hereby agree to the performance standards set forth below. Such standards shall apply to the plan recordkeeping and other administrative services Prudential is providing on behalf of the Plan. Total dollars at risk each calendar year will be capped at $7,000, in the aggregate, for shortfalls related to services Prudential provides on behalf of the Plan. In the event that Prudential fails to meet a performance standard with respect to an ongoing service for any quarter (as set forth in this Exhibit), Prudential shall make reasonable efforts to rectify the situation and celiver against met stanaarc in the next quarter. In the event that Pruoenual tans to improve its performance regarding the previously identified service within the next calendar quarter, Prudential will provide a "Reimbursement Amount" as described in this Exhibit in the subsequent quarter. In the event a Reimbursement Amount is due under this paragraph, that amount shall be (i) applied against the Plan's administrative expenses otherwise due to Prudential under this Agreement, or (ii) credited toward additional administrative services to be provided by Prudential to the Plan, or (iii) made available to the Plan to pay reasonable and actually incurred Plan administrative expenses in accordance with the terms outlined in Exhibit C of this Agreement. Service Description Service Standard Reimbursement amount Participant Services Participant Service Representatives Available $224 Phone Response Monday Through Friday 8 am to 9 pm Time ET(Excluding Holidays). Scheduled days before or after holidays the participant service center will close at 5:00 PM ET. 80% of calls answered within 20 seconds for live operator, and an abandonment rate of less than 2%. If call volumes exceed 10% of normal or budgeted volumes the month would be excluded. Quarterly Statement 98% mailed or posted to the website within ten $222 Delivery (10) business days after quarter close. Dependency: Receipt of all necessary information (example, message approval) from the City of Santa Ana 3 weeks prior to the end of the quarter for which the statement period is applicable. Loan initiations 99 % of loans processed within 2 business days $222 provided the request is received in good order by 4 p.m. ET (2 p.m. ET for transactions involving com any stock). Withdrawals, 99 % of withdrawals processed within 2 $222 Unforeseen business days provided the request is received Emergency in good order by 4 p.m. ET (2 p.m. ET for plans Withdrawals, with company stock). Rollovers out 23 25D-28 A Prudential --Row- Services Agreement Provided by PrudentiallRetirement Insurance and Annuity Company Contribution posting Prudential will post 99% of contributions and $222 repayments to participant accounts within one (1) business day of receipt of good order request. Plan Sponsor reports Data for the preceding quarter is available on $222 the plan sponsor website within 10 business days after the quarter end. Plan sponsors can create customized, ad hoc reports via the Online Retirement Center for Plan Sponsors website. This website enables you to select from a wide range of data fields to include in your report, and to submit the report request instantly. The Plan Cnnncnr ran glen olP.rf In rorai„n an n_m8il notification when the report is ready, typically within 24 hours. Participant 80 percent rating of Satisfied to Highly Satisfied $222 Satisfaction on a 4 point scale Participant Level 99% of fund transfers are processed the same $222 Investment Transfers day if initiated by 4 p.m. ET (2 p.m. ET for transactions involving company stock) In the event that Prudential fails to meet a performance standard with respect to a one-time or annual based service (as set forth in this Exhibit), Prudential will provide a "Reimbursement Amount" as described in this Exhibit in the quarter following the failure to provide the guaranteed service standard. In the event a Reimbursement Amount is due under this paragraph, that amount shall be (i) applied against the Plan's administrative expenses otherwise due to Prudential under this Agreement, or (ii) credited toward additional administrative services to be provided by Prudential to the Plan, or (iii) made available to the Plan to pay reasonable and actually incurred Plan administrative expenses in accordance with the terms outlined in Exhibit C of this Agreement. Transition Our conversion approach focuses on partnering $5000 Deliverables with you to develop a customized strategy to minimize service interruption while proactively managing and executing the conversion project. When the final participant data is received from the prior record keeper, account balances are reconciled and established on Prudential's system within three business days. We commit to having your plan transitioned according to the overall conversion schedule established with City of Santa Ana at the outset of the transition. The overall schedule will be created based on the needs of the City of Santa Ana. If we fail to complete the overall transition within the timeframes established, we will reimburse the City of Santa Ana Deferred Compensation Plan, provided that all transition stakeholders meet 24 2501-29 MID Prudential, Services Agreement Provided by Prudential Retirement Insurance and Annuity Company 25 25D-30 their commitments to the schedule and that all necessary account information is provided in good order. Annual plan report to Financial reports will be made available on the $222 client plans sponsor website within 120 days of plan yearend. 25 25D-30 Prudential RNOW PUT Trust Agreement Trust Agreement provided by Prudential Bank & Trust, FSB TRUSTAGREEMENT (GOVERNMENTAL) Establishing the CITY OF SANTA ANA DEFERRED COMPENSATION PLAN TRUST by and between CITY OF SANTA ANA and PRUDENTIAL BANK & TRUST, FSB Exhibit 2 2501-31 Prudential PBBT Trust Agreement TABLE OF CONTENTS Section 1 Establishment of Trust Section 2 General Duties of the Employer; Indemnification Section 3 Appointment and Duties of Investment Manager Section 4 General Duties of Trustee Section 5 Power and Duties of Trustee with Respect to Trust Fund Section 6 Payment of Taxes Section 7 Disbursement of Trust Funds Section 8 Expenses and Compensation of Trustee Section 9 Expenses of the Plan and Trust Fund Section 10 Accounts of the Trustee Section 11 Resignation, Removal and Substitution of Trustee Section 12 Amendment and Termination of Trust Section 13 Miscellaneous Provisions E 25D-32 PBBT Trust Agreement Prudential THIS TRUST AGREEMENT is made by and between City of Santa Ana (hereinafter called the "Employer"), and Prudential Bank $ Trust, FSB, a federal savings bank with its principal office and place of business in the City of Hartford, Connecticut (hereinafter called the "Trustee"). WITNESSETH: WHEREAS, the Employer has established or adopted for its eligible employees the City of Santa Ana Deferred Compensation Plan Trust (hereinafter called the "Plan") and serves as the Plan administrator and named fiduciary; and WHEREAS, the Employer desires the Trustee to hold Plan funds and the Trustee is willing to hold such funds pursuant to the terms of this Trust Agreement; Kinn THFPFFr1PF in rnncirloratinn of tho nromicoc pnri miiti,al r:nvonante horoin rnntainorl, tho nartiac hereto do hereby mutually declare and agree as follows: Section 1: Establishment of Trust. (a) In order to carry out the purposes of the Pian, the Employer hereby creates and establishes a trust to be known as the City of Santa Ana Deferred Compensation Plan Trust (hereinafter called the "Trust" or 'Trust Fund"). The Trustee accepts this Trust and agrees to act as Trustee hereunder, but only on the terms and conditions set forth in this Trust Agreement. Subject to the terms and conditions of this Trust Agreement, all right, title and interest in and to the estate of the Trust Fund shall be vested exclusively in the Trustee. This Trust shall be effective on October 1, 2018 or, if later, the date executed on behalf of the Trustee. This Agreement will continue in effect for a period of three (3) years from the effective date of this Agreement, unless sooner terminated in accordance with the provisions of this Agreement. In addition, the Plan Sponsor may extend this Agreement for an additional two 2 year period. (b) The Trust Fund shall include only those assets which the Trustee accepts. Only assets actually received by the Trustee will become part of the Trust Fund. The Employer acknowledges and agrees that it is responsible for effectuating the transfer of any assets held by a prior trustee or custodian to the Trustee. All assets so received, together with the income therefrom and any other increment thereon, shall be held by the Trustee pursuant to the terms of this Trust Agreement without distinction between principal and income and without liability for the payment of interest thereon. Section 2: General Duties of the Employer: Indemnification. (a) The Employer shall control and manage the operation of the Plan. The Employer shall be responsible for determining benefit rights under the Plan, instructing the Trustee in the disbursement of benefits, investment management, soliciting stock voting instructions from participants, directing the Trustee in voting proxies and performing those plan administration functions specified in the Plan. (b) The Employer shall act as custodian with respect to promissory notes, mortgages and related documents given in connection with Plan loans, if any, and the Employer or its delegate shall hold in safekeeping all such promissory notes, mortgages and related documents. (c) The Trustee shall be fully protected and shall incur no liability in acting In reliance upon the instructions or directions of the Employer, or any delegate of the Employer. In addition, the Trustee shall be entitled to rely on directions given by a Plan participant, where the Plan provisions permit such direction. Any reference herein to directions or instructions from the Employer shall include directions or instructions from any delegate of the Employer or from a Plan participant, where the Plan provisions permit such direction. a 25D-33 (d) The Employer shall indemnify and hold harmless the Trustee from and against any and all claims, losses, damages, expenses (including reasonable counsel fees) and liability to which the Trustee may be subject by reason of any act done or omitted to be done, except where the same is finally adjudicated to be due to the negligence or willful misconduct of the Trustee. (e) In addition to and in no way in limitation of the indemnification of paragraph (d), the Employer hereby agrees to indemnify and hold harmless the Trustee from and against any claims, losses, damages, expenses (including reasonable counsel fees) and liability to which the Trustee may be subject by reason of any act or omission of any prior, subsequent or existing trustee of the Plan. (f) The Employer (or another named fiduciary for contributions, if appointed by the Employer) shall have sole and exclusive responsibility for: (i) determining the amount of contributions required to be made under the Plan, (ii) monitoring and ensuring that contributions are made to the Plan in a timely manner and (iii) if required to ensure that contributions are made to the Plan, directing the Trustee with respect to the Plan's legal claims for delinquent contributions. Section 3: Appointment and Duties of Investment Manager. (a) The Employer may, in writing, appoint an Investment Manager to assume the responsibility for the investment of any portion of the assets of the funds held in the Trust for such time as the Employer may determine and, unless such power is reserved to the Employer, for directing the Trustee to vote or refrain from voting any securities held in the Trust over which the Investment Manager has investment responsibility, or to exercise or refrain from exercising any rights to subscribe for additional securities appurtenant to such securities. Appointment of an Investment Manager, or communication of such to the Employer, shall constitute an allocation to the Investment Manager of fiduciary responsibility for the part of the Trust funds subject to the Investment Manager's management and control. (b) The Employer shall ascertain and certify to the Trustee that any Investment Manager appointed hereunder is (i) registered as an investment adviser under the Investment Advisers Act of 1940; (ii) a bank, as defined in that Act; or (iii) an insurance company qualified to perform investment management services under the laws of more than one state, and that the instrument or instruments appointing an investment manager and evidencing the Investment Manager's acceptance of such appointment contains an acknowledgement by the Investment Manager that it is a fiduciary with respect to the Plan. (c) The Investment Manager(s) shall have sole responsibility for the investment and, unless reserved to the Employer, the voting and subscription action of the portion of the Trust funds under its respective management, and the Trustee shall take such action only upon the instructions of the Investment Manager. The Trustee shall not be liable for, or obligated to inquire into, the acts or omissions of any Investment Manager appointed hereunder. (d) The Investment Manager shall from time to time certify to the Trustee the name of the person or persons authorized to act on its behalf, and shall furnish to the Trustee a specimen signature of any such person. When any person ceases to have the authority to act on behalf of the Investment Manager, the Investment Manager shall promptly notify the Trustee. Until such notice is received by the Trustee, such person shall continue to be an authorized representative of the Investment Manager. (e) All directions to the Trustee by the Investment Manager shall be in writing and shall be signed by the Investment Manager or its authorized representative. Provided the Employer has previously approved, written directions from the Investment Manager may be provided through 25D-34 any mutually agreed upon electronic or facsimile communication device, and the trustee may fully rely upon the validity and authenticity thereof. (f) If an Investment Manager resigns or is removed by the Employer, the Employer shall promptly notify the Trustee and that portion of the Trust funds shall again be invested pursuant to the instructions of the Employer until another Investment Manager has been appointed with respect to that portion of the Trust funds. Section 4: General Duties of Trustee. (a) The Trustee shall receive, hold, manage, invest and reinvest the Trust Fund pursuant to the provisions of this Section and Section 5 in accordance with the directions of the Employer. The Trustee shall take no action except pursuant to directions received by it from the Employer, and shall have no duty to determine any facts or the propriety of any action taken or omitted by it in good faith pursuant to instructions from such persons. (b) The Trustee shall be responsible, pursuant to client direction, only for such assets as are actually received by it as Trustee hereunder. The Trustee shall have no duty or authority to ascertain whether any contributions should be made to it pursuant to the Plan, nor shall it have any responsibility concerning the amount of any contribution or the application of the Plan's contribution formula.. The Trustee shall be obligated to take actions to enforce the Plan's claims for delinquent contributions solely upon the direction of either (i) the Employer or (ii) another named fiduciary for contributions who has been designated in accordance with the Plan. (c) The duties and obligations of the Trustee hereunder shall be limited to those expressly imposed upon it by this Trust Agreement notwithstanding any reference herein to the Plan, and no further duties or obligations of the Trustee, such as a duty to value Plan investments, determine the prudence of any Plan investment, or diversify Plan investments, shall be implied. The Trustee shall not be liable in discharging its duties hereunder if it acts in good faith and in accordance with the terms of this Trust Agreement and in accordance with applicable Federal or state laws, rules and regulations. The Trustee shall have no responsibilities, duties and obligations with respect to any assets not held under this Trust, even if those assets are held as assets of the Plan under a separate trust agreement. Any duties and obligations arising from such assets shall be solely those of the trustees named in such separate trust agreement, or, in the event no such separate trust exists, the plan sponsor. Section 5: Power and Duties of Trustee with Respect to Trust Fund. The Trustee shall have the following powers and duties regarding the Trust Fund: (a) To hold title to the assets of the Trust Fund, which may include entering into depository arrangements for the safekeeping of records relevant to the ownership of such assets with any bank or banks as the Trustee may choose. Without limiting the generality of the foregoing, the Employer specifically directs the Trustee to appoint, and the Trustee hereby appoints the Employer or its delegate to act as custodian with respect to promissory notes, mortgages and related documents given in connection with Plan loans, if any. (b) To invest the assets of the Trust Fund in such investment vehicles as directed by the Employer, including Plan loans made to participants, and annuity or insurance contracts issued by affiliates of the Trustee, in accordance with directions received from the Employer, and to agree to amendments to such annuity or insurance contracts, as directed by the Employer. The Trustee shall have no duty or responsibility to determine the appropriateness of any plan investment, or to cause such investments to be changed. Notwithstanding any other provision of this Agreement, all notices, proposed contract amendments, rate or fee changes or other 2501-35 communications regarding all group annuity contracts that are assets of the Plan, including any group annuity contract issued by an affiliate of the Trustee, will be sent directly by the issuer of the contract to the Employer or forwarded by the Trustee to the Employer, and the Trustee shall act on behalf of the Plan with respect to any such notice, proposed amendment, change or other communication only in accordance with the written direction of the Employer. Any rights of a contractholder under any such group annuity contract to discontinue, amend or otherwise modify the contract shall be exercised only upon the specific written direction of the Employer to the issuer of the contract or by the Trustee at the Employers specific written direction. (c) To make transfers among investment vehicles or disbursements from the Trust Fund as directed by the Employer. The Trustee shall be entitled to rely on such direction, and shall have no responsibility to ascertain whether the Plan permits such a transfer or disbursement. (d) To delegate to third parties, including affiliates of the Trustee, any or all of its duties hereunder, including recordkeeping, reporting, and proxy voting. Also, the Trustee may utilize the services of outside custodians to hold on the Trustee's behalf any Plan assets invested in securities. (e) To vote securities proxies as directed by the Employer, or by another named fiduciary or investment manager designated by the Employer. The Trustee shall not be responsible, however, for providing securities proxy tabulation services. (f) The Trustee shall discharge its duties with respect to a plan solely in the interest of the participants and beneficiaries and with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims. Section 6: Payment of Taxes. The Trustee shall pay out of the Trust Fund income taxes and other taxes of any and all kinds levied or assessed under existing or future laws against the Trust Fund, or against any person with an interest in the Trust Fund. Section 7: Disbursement of Trust Funds. (a) Upon receipt of written direction of the Employer, the Trustee shall make payments from the Trust Fund to such persons or direct its affiliate that is providing recordkeeping services to make such payments in such manner and in such amounts as the Employer shall direct in writing, and amounts paid pursuant to such direction shall no longer constitute a part of the Trust Fund. Notwithstanding the foregoing, the Employer expressly reserves the right to provide direction directly to the affiliate of the Trustee providing record keeping services regarding payments of Plan benefits or other disbursements. (b) At no time prior to the satisfaction of all liabilities with respect to participants and beneficiaries under this Trust shall any part of the corpus or income of the Trust Fund be used for, or diverted to, purposes other than for the exclusive benefit of plan participants or beneficiaries. Except as provided in the Plan, the assets of the Trust Fund shall never inure to the benefit of the Employer and shall be held for the exclusive purpose of providing benefits to participants in the Plan and their beneficiaries, and defraying reasonable expenses of administering the Plan. Section 8: Expenses and Compensation of Trustee. The Trustee shall be compensated in accordance with the fee provided to the Employer. The Trustee shall be entitled to reimbursement from the Plan for any and all costs and expenses incurred in taking actions to collect delinquent contributions and to engage and pay from the Trust Fund legal counsel, collection agents, or such other agents or advisors as the Trustee may determine appropriate in taking actions to collect delinquent contributions. In addition the Trustee shall be paid its reasonable expenses, 25D-36 including reasonable expenses of counsel and other agents employed by the Trustee, incurred in conjunction with the administration of the Trust Fund. If the Trustee proposes an amended fee schedule and the Employer fails to object thereto within ninety (90) days of its receipt, the fee of 4.9% bps, shall be deemed accepted by the Employer. Section 9: Expenses of the Plan and Trust Fund. If permitted by the Plan, the reasonable expenses relating to the Plan and Trust Fund shall be paid by the Trust, except to the extent paid by the Employer. Such expenses shall include, without limitation, actuarial, investment management, accounting, legal and Trust expenses. Section 10: Accounts of the Trustee. The Trustee has accepted this Trust on the condition that the Employer has entered or is entering into a service agreement with an affiliate of the Trustee whereby an affiliate of the Trustee will provide recordkeeping services for all Plan assets held pursuant to this Trust Agreement. The Trustee shall be ICIiUIIGU lu illi VJiIIU iU Ulu LIIIiIIV)Vi, Ui IGy,i iiu ail wimal0 VI IIID IluJlt9G tU IIII YrWu lV 41G Lnljllvy 4l, li,G recordkeeping reports and related financial information provided by an affiliate of the Trustee, but the Trustee shall not otherwise be required to provide Trust accounts. Section 11: Resignation, Removal and Substitution of Trustee. (a) The Trustee may resign at any time by giving at least 60 days' written notice to the Employer (unless the Employer deems notice of a shorter duration to be adequate). The Employer may remove the Trustee at any time by giving at least 60 days' written notice to the Trustee (unless the Trustee deems notice of a shorter duration to be adequate). (b) The Trustee's service pursuant to this Agreement is conditioned upon the existence of one or more contracts between the Employer or the Plan (or the Trustee on behalf of the Employer or the Plan) and a subsidiary or affiliate of Prudential Financial, Inc. providing a funding medium for the Plan or providing for full Plan recordkeeping services. In the event the contract providing a funding medium or providing for recordkeeping services is discontinued or terminated, this Agreement shall be terminated as well with no further notice from either party to the other as of the date of discontinuance or termination of the contract providing a funding medium or providing for recordkeeping services. (c) Any successor trustee hereunder may be either a corporation authorized and empowered to exercise trust powers or may be one or more individuals. (d) Upon the appointment of a successor trustee, the resigning or removed Trustee shall execute, acknowledge and deliver all documents and written instruments necessary to transfer and deliver the Trust Fund and all rights and privileges therein to the successor trustee. Upon the appointment of a successor trustee, the resigning and removed Trustee shall be discharged from further accountability for the Trust Fund, and shall be under no further duty, obligation or responsibility for the disposition by such successor trustee of the Trust Fund or any part thereof. Section 12: Amendment and Termination of Trust. (a) The Employer and the Trustee may mutually agree at any time to amend this Trust Agreement and the Trust created hereby to any extent deemed advisable. No amendment to this Trust Agreement shall be effective unless mutually agreed to in writing by the Employer and the Trustee; provided, however, that Trustee's fee schedule may be amended as provided in Section 8. (b) The Employer may at any time revoke this Trust Agreement and terminate the Trust hereby created. Such revocation and termgr)ation shall) become effective upon receipt by the Trustee or 25D-37 its delegate of a written instrument of such revocation and termination executed by the Employer. Upon such termination, disposition of the assets of the Trust Fund shall be governed by the terms of the Plan. The Employer agrees in writing with the Trustee to indemnify the Trust Fund for any taxes or other penalties which may be assessed against it as a result of such termination or agrees to provide a bond to secure payment of any such taxes or penalties. Section 13: Miscellaneous Provisions. (a) This Trust Agreement and the Trust hereby created shall be governed, construed, administered and regulated in all respects under the law of the United States and the State of California. (b) The titles of the Sections in this Trust Agreement are for convenience of reference only and in case of any conflict, the text of this instrument, rather than such titles, shall control. (c) In case any provisions of this Trust Agreement shall be held illegal or invalid for any reason, their illegality or invalidity shall not affect the remaining parts of this Trust Agreement, and this Trust Agreement shall be construed and enforced as if the illegal and invalid provisions had never been a part of the Trust Agreement. (d) This Trust Agreement may be executed in any number of counterparts, each of which shall be deemed an original. The counterparts shall constitute one and the same instrument and may be sufficiently evidenced by any one counterpart. (e) This Trust Agreement shall be binding upon the respective successors and assigns of the Employer and the Trustee. (f) Neither the gender nor the number (singular or plural) of any word shall be construed to exclude another gender or number when a different gender or number would be appropriate. (g) In the event of any conflict between provisions of the Plan and those of this Trust Agreement, this Trust Agreement shall prevail. Provisions in other documents, including but not limited to plan documents, group annuity contracts, and/or service agreements, that might otherwise reflect the powers, duties, and responsibilities of the Trustee, shall in no way supersede or replace any of the provisions contained in this Trust Agreement. This Trust Agreement shall constitute the entire agreement between the Employer/Plan Administrator and the Trustee. (h) Communications to the Trustee shall be sent to the Trustee's principal offices or such address as the Trustee may specify in writing. No communication shall be binding upon the Trustee until it is received by the Trustee or its delegate. Communications to the Employer shall be sent to the Employer's principal offices or such address as the Employer may specify in writing. (i) Insurance. Prudential shall at all times during the term of this Agreement, at its own cost and expense, carry and maintain commercially reasonable insurance coverage, including the insurance policies listed below. • Worker's Compensation and Employer's Liability insurance, with statutory limits for workers' compensation and Employers Liability limits of $1,000,000 per accident. • Commercial General Liability insurance, insuring against claims for bodily injury, property damage, completed operations and contractual liability with a limit of $1,000,000 per occurrence and $2,000,000 in the aggregate. • Automobile Liability insurance covering all owned, non -owned, hired and leased vehicles used in the performance of this Agreement with a combined single limit of $1,000,000. • Casualty Umbrella or Excess Liability follow -form insurance in the amount of $5,000,000. • Professional Liability or Errors & Omissions insurance with limits of at least $5,000,000 each claim or wrongful act with a $250,000,000 deductible. • Fidelity Bond or Comprehensive Crime insurance covering employee dishonesty with limits of at least $5,000,000 each claim with a $250,000,000 deductible. • Cyber Risk or Privacy Liability insurance with limits of at least $5,000,000 each claim or wrongful act with a $250,000,000 deductible. Prudential will be solely responsible to pay and determine the deductibles on these insurance policies, which will be issued by insurance carriers with an A.M. Best rating of A- or better. In the event that any of the above-described insurance policies are written on a claims -made basis, then such policy or policies shall be maintained during the entire period of the Agreement and for a period of two (2) years following the termination or expiration of the Agreement. Prudential will provide reasonable notice of any material adverse change or cancellation of the S above-described insurance coverage. Authorizing Plan Fiduciary shall be included as an additional insured on the above -referenced policies. Certificates of insurance matching the terms of this § 9 will be provided upon Authonzin Plan Fiduciary's reasonable written request. This § 9 does not limit or exoand Prudential'i,en obligations. IN WITNESS WHEREOF, this Trust Agreement has been executed on the dates indicated below. The persons executing this Trust Agreement represent that they are duly authorized to do so. EMPLOYER By Soo Atraript] Signature Page Date PRUDENTIAL BANK & TRUST, FSB 0 Title Date 25D-39 ATTEST: MARIA HUIZAR Clerk of the Council APPROVED AS TO FORM: SUN iA ll. UAit V tiLHU City Attorney Bv4C wla, A- 'KlS✓�A" Laura A. Rossini Senior Assistant City Attorney RECOMMENDED FOR APPROVAL: CITY OF SANTA ANA RAUL GODINEZ, II City Manager FRANCISCO GUTIERREZ Executive Director of Finance and Management Agency .ju(. pol".y „, 25D-40 INVESTMENT AGREEMENT issued by PRUDENTIAL RETIREMENT INSURANCE AND ANNUITY COMPANY a wholly owned subsidiary of The Prudential Insurance Company of America 280 Trumbull Street, Hartford, Connecticut 06103 I►\ _ ul ► _' 1 � �i SIC ����' ISSUED TO: Prudential Bank & Trust, FSB, as Trustee of the City of Santa Ana Deferred Compensation Plan Trust EFFECTIVE DATE: October 1, 2018 ISSUE DATE: This Agreement is a group annuity contract that funds benefits for plans qualified under section 457 of the Internal Revenue Code and is designed to comply with state insurance department standards. Annuities are available subject to the terms of each plan. However, this Agreement does not require the purchase of annuities. Prudential Retirement Insurance and Annuity Company ("PRIAC") will accept Deposits of Plan assets and pay Benefits under the terms of this Agreement. The entire Agreement consists of the Application and the provisions of this Agreement. PRIAC issues this Agreement in consideration of the Application and the payment of Deposits provided for under this Agreement. Payments and values that are based on the investment experience of a separate account (other than a guaranteed separate account) are variable and are not guaranteed. The operation of each separate account is described in. this Agreement. In Witness Whereof, PRIAC has executed this Agreement on the Issue Date, to take effect on the Effective Date. President GA -2020 -IA -0805 Exhibit 3 25D-41 City of Santa Ana - Investment Agreement (specimen).doc TABLE OF CONTENTS Sections of Base Agreement 1 Deposits..................................................................... Starting on Page 2 Transfers Between Plan Investment Options..............................................:.3 3 Distributions...................................................................................................4 -5 4 Operational Agreements................................................................................6- 5 Termination....................................................................................................7 6 Miscellaneous................................................................................................9 7 Annuities...................................................................:...:................................11 8 Definitions ..........................................................:...................:.......................13 Expense Schedule Following Base Agreement: Guaranteed Income Fund Investment Addendum Universal Separate Account E Investment Addendum Application e weM?rence .,)- !!eierence GA -2020 -IA -0805 I City of Santa Ana - Investment Agreement (specimen).doe 25D-42 SECTION 1 -DEPOSITS 1.1 CONTRIBUTIONS. Subject to the terms of the Plan, the Investor ("You") will deposit Contributions that are directed for investment under this Agreement. You may reduce the amount of Contributions by Plan distributions to Participants for any contribution period. 1.2 MINIMUM CONTRIBUTIONS. PRIAC ("We", "Our" or "Us") may require a minimum amount of Contributions for investment under this Agreement, in any one Plan year, equal to $35,000. 1.3 TRANSFERRED ASSETS. You will deposit amounts contributed under the terms of the Plan prior to the Effective Date of this Agreement that are directed for investment under this Agreement. Subject to the terms of the Plan and as permitted by the Code, and subjecfto Our agreement to accept such transfers, You will deposit amounts transferred from other plans that are directed for investment under this Agreement. For purposes of this section, "plans" shall include any "eligible retirement plan" as, defined in Code section 402(c)(8). 1.4 TIMING OF CONTRIBUTIONS AND TRANSFERRED ASSETS. You will deposit Contributions and Transferred Assets within thirty-one (3 1) days of the date specified in the Plan. However, We will allow a grace period of thirty-one (3 1) days or, if less, the time required by law for Contributions. You and the contributing employers will ensure that all Contributions due under the Plan are made within the time required by law. 1.5 ROLLOVERS. Subject to the terms of the Plan and as permitted by the Code, and subject to Our agreement to accept such rollovers, You will deposit rollover amounts from other plans that are directed for investment under this Agreement. For purposes of this section, "plans" shall include any "eligible retirement plan" as defined in Code section 402(c)(8).. 1.6 ACCEPTANCE',OF DEPOSITS. We will only accept Deposits specified in the preceding paragraphs. 1.7 ALLOCATION DATE FOR DEPOSITS. We will allocate Deposits as of the valuation date coinciding with or next following the date We receive the Deposits. The applicable Investment Addendum specifies the valuation date. GA -2020 -IA -0805 25D-43 City of Santa Ana - Investment Agreement (specimen).doc SECTION 2 - TRANSFERS BETWEEN PLAN INVESTMENT OPTIONS 2.1 TRANSFERS. Subject to the terms of the Plan, Participants may direct Transfers between Plan investment vehicles, including any investment vehicle described in an Investment Addendum under this Agreement. We will apply any limitations described in the Base Agreement or in the applicable Investment Addendum under this Agreement to these Transfers. Participants must independently choose to make Transfers between Plan investment options, free from corporate or trustee suggestion or persuasion. 2.2 ALLOCATION DATE FOR TRANSFERS. We will allocate Transfers between investment vehicles as of the valuation date coinciding with or next following the later of (A) the date We receive instructions from You or a Participant regarding the Transfer, or (B) the effective date of the Transfer. The applicable Investment Addendum specifies the valuation date. You and We will mutually agree on a method for submitting Transfer instructions. GA -2020 -IA -0805 25D-44 ....r �:elarenoe City of Santa Ana - Investment Agreement (specimen).doc SECTION 3 - DISTRIBUTIONS 3.1 GENERAL DISTRIBUTIONS. Subject to the terms of the Plan, We will make Distributions for Benefit payments from an investment vehicle(s) under this Agreement. We will apply to these Distributions any limitations described in the Base Agreement or in the applicable Investment Addendum under this Agreement. We will make Distributions in the following manner: (A) TRUSTEE. If the Plan has a trustee, the trustee may, but is not required to, receive all cash payments for further distribution. (B) AMOUNT. A Distribution may be an amount up to and including the value of Plan assets in the investment vehicle(s) on the valuation date. The applicable Investment Addendum specifies the valuation date. (C) FORM. Subject to the terms of the Plan, and as instructed by You, We will make Distributions in one or a combination of the following forms: (a) Any type of annuity that We agree in writing to provide, in accordance with the provisions of Section 7; (b) Single sum cash payment; or (c) A series of cash payments over a period of time. Subject to the terms of the Plan, if the Participant's account balance does not exceed $5000, We will make any Distribution in the form of a single sum cash payment. While an annuity is available as a form of Distribution, We will not require You to purchase an annuity under this Agreement. 3.2 DISTRIBUTIONS UPON DEATH. If a Participant dies prior to distribution of his interest in the Plan, You will approve the amount of the death benefit and advise Us of the following: (A) the designated beneficiary(ies); and (B) the form of benefit to be paid in accordance with the provisions of the Plan and applicable law. 3.3 DEFERRED PAYMENTS. In the event of severe adverse economic conditions, We may defer a Distribution under this Section in accordance with the terms of the applicable Investment Addendum. We will only defer the Distribution for a maximum period of six (6) months from the original distribution date. We will defer the Distribution to a date that is less than six (6) months if We determine that the period of severe adverse economic conditions has ended. We will only defer the payment within the time GA -2020 -IA -0805 25D-45 City of Santa Ana - Investment Agreement (specimen).doc permitted by applicable law. Regardless of adverse economic conditions, We will never defer a Distribution due as a result of a Participant's retirement, termination of employment, disability, death, Distributions required by Code Section 401(a)(9) or withdrawals for unseen emergencies as permitted under the Plan. 3.4 PROVISIONS NOT APPLICABLE UPON TERMINATION. With the exception of Section 3.3, the distribution provisions described in this Section 3 do not apply if the Agreement is terminated. Upon termination of this Agreement, We will apply the provisions of Section 5 along with provisions under the applicable Investment Addendum. -„e GA -2020 -IA -0805 25D-46 City of Santa Ana - Investment Agreement (speciram).doc SECTION 4 - OPERATIONAL AGREEMENTS 4.1 QUALIFICATION. If required by law and by the date required by law, the Plan Sponsor will apply for a determination letter from the Internal Revenue Service that a new Plan meets the requirements of Code section 457. If the Plan is amended and there are material modifications to the Plan, the Plan Sponsor will apply for a new determination letter from the Internal Revenue Service if required by law and by the date required by law. You will provide a copy of the determination letter to Us within thirty (30) days after it is received by the Plan Sponsor from the Internal Revenue Service._ 4.2 PLAN CHANGE OR AMENDMENT. You will provide Us with reasonable advance notice of any change or amendment to the Plan. The Plan Sponsor may only adopt a change or amendment that would not have an adverse financial effect on the Agreement or on Us. We will determine whether a change or amendment has such -an adverse effect. 4.3 DISQUALIFICATION. You will notify Us within thirty (30) days after the Plan Sponsor receives initial written notification from the Internal Revenue Service that the Plan no longer meets the requirements of Code section 457. ' When this determination becomes final, We will terminate this Agreement under the term's of Section 5. 4.4 PLAN OPERATION. You will ensure that the Plan operates in compliance with all applicable laws and regulations. 4.5 INFORMATION. You will submit all information necessary to process Deposits, Transfers, and Distributions as frequently as You and We mutually agree. You will properly authorize and promptly. forward any information required by Us to meet an obligation under this Agreement. In addition, upon Our request, You will promptly forward any information required by Us to ensure compliance with the provisions of Section 2.1. As proof of death, We may require a copy of the death certificate, a physician's written statement certifying the death of the decedent, a copy of a certified decree of a court of competent jurisdiction as to the finding of death, or any other reasonable evidence. 4.6 EXPENSES. You will pay expenses and charges described in the Expense Schedule within thirty (30) days after the mailing date of the expense notification, or by another method to.which You and We mutually agree. We may deduct the amounts owed from Plan assets invested under this Agreement if You do not pay expenses and charges within thirty (30) days, and the Plan permits the expenses and charges to be deducted from Participant accounts. We will provide you with advance written notification of the deduction. We may also terminate this Agreement for non-payment of Expenses under the terms of Section 5. 4.7 REPORTS. We will provide You with reports of activity under this Agreement as frequently as You and We mutually agree. " CIVItLn iu. CCUllUtlil� GA -2020 -IA -0805 25D-47 City of Santa Ana - Investment Agreement (specimea).doc SECTION 5 - TERMINATION 5.1 TERMINATION. We will terminate this Agreement under the following circumstances: (A) You notify Us in writing that the Agreement will be terminated; (B) We notify You in writing that the Agreement will be terminated because You have materially breached a provision of Section 1,.2; 3, 4, or 6, or a provision of an Investment Addendum and You have failed to cure such breach after We have given you a reasonable opportunity to do so; (C) We notify You in writing that the Agreement will be terminated . because You have not paid Expenses and You have not made alternative arrangements with Us for paying the Expenses as provided under Section 4.6; or (D) We determine that the class of business to which, this Agreement belongs is no longer commercially desirable and We notify all investors of this class of business in writing that the agreements will be terminated. 5.2 TERMINATION DATE. The Termination Date is the first day of the month coinciding with or next following (i) the later of the date You specify in your notice pursuant to Section 5.1(A) or the date We receive such notice, (ii) thirty (3 0) days after the later of the date We specify in Our notice to You pursuant to Section(s) 5.1(B), 5.1(C) or 5.1(D) or the date We send the notice. Upon termination of the Agreement, We will (A) no longer accept Deposits under the Agreement as of the Termination Date, and (B) notify You of Expenses due as soon as practicable following the Termination Date. 5.3 TERMINATION DISBURSEMENT DATE. Unless You and We agree to an alternative date, We will initiate Termination Disbursements no later than the Termination Disbursement Date which is the valuation date coinciding with or next following the later of: (A) Ninety (90) days after the date We receive all information necessary to make the Disbursement; or (B) Ninety (90) days after the date We recover all outstanding Expenses under this Agreement. The applicable Investment Addendum specifies the valuation date. GA -2020 -IA -0805 7 City of Santa Ana - Investment Agreement (specimmidoc 25D-48 5.4 TERMINATION DISBURSEMENTS. On the Termination Disbursement Date, We will disburse, or begin to disburse all assets held under this Agreement. Any limitations under the applicable Investment Addendum will apply to these Termination Disbursements. We will recover any Expenses incurred under the Agreement up to the Termination Disbursement Date. We will disburse all assets from the investment vehicle(s) as follows: (A) If the Plan continues to meet the requirements of Code section 457 but a new funding agent is selected, You may direct Us to transfer the assets to the Plan's trustees or new funding agent. You or another authorized Plan representative must give Us written instructions regarding the Termination Disbursement. We may also require that You or another authorized Plan representative provide Us with written confirmation that the Plan will continue to meet the requirements of Code section 457. (B) If the Internal Revenue Service determines that the Plan initially fails to meet the requirements of Code section 457, We will disburse the Plan assets in a single sum cash payment. (C) If the Plan is terminated or the Internal Revenue Service determines that the Plan no longer meets the requirements of Code section 457, We will disburse the Plan assets as You and We mutually agree. If government approval is required, We may require that You or another authorized Plan representative provide Us with written confirmation that the Plan Sponsor has received any required government approval before We disburse the assets. GA -2020 -IA -0805 25D-49 City of Santa Ana - rove trnent Agreement (speoimen).doc SECTION 6 - MISCELLANEOUS 6.1 You will address all communications in writing (by first class mail, postage prepaid) or as You and We mutually agree. You will submit communications to Us at the following address: Defined Contribution Administration Prudential Retirement Prudential Retirement Insurance and Annuity Company P.O. Box 2975 Hartford, CT 06104 We will submit communications to You at the Investor's principal place of business or as You and We mutually agree. 6.2 You and We (including any entity which may succeed Us or any entity to which this Agreement may be assigned) are obligated to comply,with all terms of this Agreement unless the State of Connecticut determines that We have ceased doing this type of business. 6.3 A Distribution or Termination Disbursement payable to any Participant or beneficiary is only assignable if the law allows it. All Distributions or Termination Disbursements are exempt from the claims of creditors to the extent the law permits. 6.4 We agree only to the provisions of this Agreement and We are not a party to, and are not bound by, any trust or plan.. We are not responsible for the effect of any state or Federal revenue law on any Contribution made under the Plan. 6.5 You release Us from any liability for any payments that We made under this Agreement and in accordance with the terms of the Plan and applicable law. 6.6 We may rely conclusively on reports, notices, requests and other information submitted by You, the Investor's designated representative, a Participant or a beneficiary. 6.7 We will notify You upon becoming aware that any premium tax will be assessed on amounts deposited under this Agreement. We may deduct this tax and any interest due on this tax from Deposits or from Plan assets held under this Agreement. 6.8 In applying for the Agreement, You will select the Investment Addendum (Addenda) which become(s) part of this Agreement. 6.9 Any change to this Agreement will be subject to the following provisions: (A) No change will affect the amount of interest credited or accrued prior to the effective date of -the change. GA -2020 -IA -0805 25D-50 City of Santa Ana - Investment Agreement (specimen).doc (B) No change will affect the amount or terms of any annuity purchased prior to the effective date of such change. (C) Any change to this Agreement may be made without notice to or the consent of any Participant, beneficiary or annuitant. (D) We may, at any time, revise the provisions of this Agreement if the revision is required to comply with Code section 457, or any applicable law or regulation issued by a governmental agency. If required by law, the revision will be retroactive. (E) We may annually review and revise the provisions of this Agreement unless otherwise provided in the Base Agreement or the Investment Addendum (Addenda). We will provide You ninety (90) days advance written notice before We revise the provisions of the Agreement. Upon receiving the advance written notice, You may elect to terminate the Agreement under the provisions of Section 5 and the applicable Investment Addendum. 6.10 The laws of the State of Connecticut govern this Agreement except where its provisions may be superseded by the laws of its state of issuance. 6.11 The singular includes the plural and the masculine or feminine pronoun includes both the masculine and feminine gender unless the context indicates otherwise. 6.12 Two or more duplicate originals of this Agreement constitute one and the same instrument. The entire Agreement between You and Us consists of the Application together with all Investment Addenda and Schedules that We have attached to and made part of this Base Agreement. 6.13 If any payment due hereunder by PRIAC is otherwise due to be paid on a date when PRIAC is closed for business, We will make such payment on Our next normal business day. GA -2020 -IA -0805 10 City of Santa Ana - Investment Agreement (specimen).doc 25D-51 SECTION 7 - ANNUITIES 7.1 You may, but are not required to, purchase an annuity under this Agreement. We will reduce the amount We apply to purchase an annuity by any amount necessary to pay applicable taxes and/or annuity purchase fees. We will provide any retirement annuity based on Our existing business practices and rates then in effect for agreements in the same class of business as this Agreement. 7.2 We may require proof that the recipient of annuity payments is living as of each and every date on which any annuity payment becomes payable. We may withhold payments until We receive the requested proof. 7.3 We will issue an individual certificate to each Participant for whom an annuity is purchased. Also, if the state where We issue this Agreement requires, We will issue a certificate to each Participant contributing to the Plan., Any certificate issued will not cancel or alter any terms of this Agreement. 7.4 If We discover that the annuitant's age or any other fact pertaining to the purchase or determination of an annuity amount was misstated, or We discover a clerical error, We will make the following adjustments: (A) We will correct the amount of annuity payable retroactively to the date We purchased the annuity; (B) We will deduct any overpayments resulting from misstatements or errors from amounts payable following the correction of the annuity amount; (C) We will pay any underpayments resulting from misstatements or errors in full with the next payment following the correction of the annuity amount. 7.5 We guarantee that We will purchase annuities on an actuarial basis that is at least equal to the following actuarial basis for a fixed annuity. (A) Form of Annuity: 100% Fixed Life Annuity Actuarial Assumptions: Mortality - 1950 Male Group Annuity Valuation Table, with age setback of 4.8 years plus one-fifth of the number of years from 1895 to the annuitant's year of birth; Interest - 2%; Loading — 8.25%. We will review this guaranteed actuarial basis annually and may change it after We give ninety (90) days' advance written notice to You. We may only change the guaranteed actuarial basis following the first twelve (12) months after the Agreement's Effective Date. We may only change it once in any twelve (12) month period unless You and We agree in writing to make an exception. UL .!l it a 1 u. GA -2020 -IA -0805 1 1 City of Santa Ana - Investment Agreement (specimea).doc 25D-52 SECTION 8 — DEFINITIONS "Agreement" is the Investment Agreement, including the Base Agreement, Investment Addendum (Addenda) and Application. "Base Agreement" includes Sections 1 through 8 and the Expense Schedule. "Benefit" is any payment to which a Participant is entitled under the terms of the Plan. "PRIAC" is Prudential Retirement Insurance and Annuity Company. "Code" is the Internal Revenue Code of 1986, as amended from time to time. "Contributions" are amounts contributed under the terms of the Plan on or after the -effective date of this Agreement. "Deposits" are Contributions, Transferred Assets and Rollovers described in Section I. "Distributions" are withdrawals for Benefit payments described in Section 3. "Expenses" are expenses and charges described in the Expense Schedule. "Investment Agreement" is a group annuity contract, GA -)D=, issued by PRIAC. "Investment Addendum" describes each investment vehicle available under the Agreement, as You select, and all conditions associated with the use of the investment vehicle under this Agreement. "Investor" is Prudential Bank & Trust, FSB, as Trustee of the City of Santa Ana Deferred Compensation Plan Trust, the Plan Sponsor, or any person designated by the Investor or the Plan Sponsor to carry out its administrative functions. "Participant" is an individual having an account under the Plan. "Plan" is City of Santa Ana Deferred Compensation Plan, as adopted by the Plan Sponsor, effective, as constituted on the Effective Date of this Agreement, and as amended from time to time. "Plan Sponsor" is the entity sponsoring the Plan. "Termination Disbursements" are amounts payable from an investment vehicle(s) under this Agreement upon termination of this Agreement as described in Section 5. "Transfers"'arc.Participant-directed transfers (described in Section 2.1) between Plan investment vehicles. "You" refers to the Investor. "We", "Our" or "Us" refers to PRIAC. GA -2020 -IA -0805 12 City of Santa Ana - Investment Agreement (specimea).doc 25D-53 EXPENSE SCHEDULE Effective October 1, 2018, the Expense Schedule is as follows: INVESTMENT FUNDS ASSET CHARGES Part I — A Payment Method (left-most column) Key: Charges that are labeled "OT" are billed directly to the Plan Sponsor on a quarterly basis. Charges that are labeled "OA" are deducted from the gross rate of fixed funds and deducted from the gross unit value for the market valued funds. Charges stated below are annual charges. OA Guaranteed Income Fund OA Core Bond/PIM Fund .XXW .XX% GA -2020 -IA -0805 I City of Santa Ana- Investment Agmement(specimen).doc 25D-54 EXPENSE SCHEDULE Part 11-A Asset Charges The Asset Charges for the investment funds listed in Part I -A of the Expense Schedule are annual charges deducted from the declared rate or unit value of individual investment funds on a daily basis. As used below, the term "You" refers to the Plan Sponsor and the terms "Us" and "Our" refer to Prudential. Retirement Insurance and Annuity Company. Asset Charges, where applicable, are imposed to cover certain of Our expenses incurred in connection with the establishment and maintenance of the Agreement and providing administrative services for ,the Plan. Asset Charges may also be used to cover payments made by Us at Your direction to other service providers. In no event will these charges cover or be amended so as to cover any fees, expenses, taxes or charges relating to the management of the assets held hereunder. If You request Us to pay the expenses of another service provider or request Us to reimburse You for Plan expenses, a separate agreement will be signed by You. The Expense Schedule is subject to annual review by Us and may be changed effectively after ninety (90) days' written notice to You. The Schedule will not be changed within,the first twenty four (24) months following the Agreement's Effective Date, nor will it be changed more frequently than once in any twelve (12) month period except by written agreement between You and Us. The Asset Charges for the funds or family of funds are listed on Part I -A of this Expense Schedule. Other Expenses/Charges We may pay commissions in connection with this contract as disclosed to You in a separate disclosure document. From time to time We may consent to pay money or to give other value to You or Your representatives. Money that We may consent to pay may include allowances or reimbursements paid to You, or to third parties for Your benefit, in connection with services rendered to You or costs incurred by You in connection with Your administration of the Plan. Value that We may consent to give may include educational and reasonable entertainment events that assist You or Your representatives in the discharge of Your duties as a plan sponsor. Separately, apart from Plan activities, We may also at Your request contribute to Your employee appreciation, charitable, educational or entertainment events. In addition, We or Our affiliates may provide compensation, payments and/or incentives to firms that furnish marketing, sales and/or other services to Us in connection with Our products. Such services may include Prudential's participation in seminars or conferences sponsored by such frons. GA -2020 -IA -0805 25D-55 City of Santa Ana - Investment Agreement (specimen).doc GUARANTEED INCOME FUND INVESTMENT ADDENDUM 1.1 GUARANTEED INCOME ACCOUNT. The term Guaranteed Income Account (hereinafter "GIA") refers to assets invested under this Agreement in the Guaranteed Income Fund. These assets are invested in Prudential Retirement Insurance and Annuity Company's (PRIAC's) general account. 1.2 MAXIMUM DEPOSITS. If PRIAC's current guidelines establish a maximum amount that can be deposited to the GIA in any one Plan year, We will communicate the maximum amount to You. You may only deposit up to the maximum amount unless We give You prior written consent to deposit amounts in excess of the maximum. 1.3 CREDITED INTEREST. We will credit interest to the GIA daily. We will credit interest to each dollar in the GIA (A) from the Valuation Date on which it is allocated to the GIA under Section 1.7 and Section 2.2 of the Base Agreement, and (B) until the Valuation Date as of which We transfer, distribute or disburse each dollar from the GIA. We will notify You of the interest rate that We will credit to the GIA for this class of business as of the date this Addendum becomes part of the Agreement (the "Declared Interest Rate"). Thereafter, We will announce a Declared Interest Rate semi-annually, effective January 1 and July 1, and that rate will be guaranteed against change during each six (6) month period. The Declared Interest Rate will always be greater than or equal to one and one half percent (1-1/2%) (the "Minimum Interest Rate"). The Declared Interest Rate is stated on an annual effective rate basis. This method for computing interest uses daily compounding so the amounts held in the GIA for 365 days (366 days during a leap year) will increase at the stated annual effective rate. 1.4 ASSET CHARGE. We will convert the annual Asset Charge under this Agreement's Expense Schedule to a daily equivalent. We will reduce the daily equivalent of the Asset Charge from interest being credited to the GIA under the preceding Section 1.3. As described in the Base Agreement, You have the option to pay the Asset Charge as an alternative to reducing the daily equivalent of the Asset Charge from interest being credited to the GIA. 1.5 VALUATION. The value of the GIA is an amount equal to (A) minus (B) where (A) is the sum of (i) Deposits to the GIA, GA -2020 -GIF -FS -0805 25D-56 Addend=457single_PRIAC_2020-GIF-FS-0805 (ii) Transfers to the GIA from another Plan investment vehicle, and (iii) Credited Interest, and (B) is the sum of (i) Expenses, if any, and (ii) Transfers, Distributions or Termination Disbursements from the GIA. 1.6 VALUATION DATE. For purposes of valuing the GIA, the term Valuation Date refers to each day that We are open to transact normal business. 1.7 DEFERRALS. We may defer Transfers, Distributions or Termination Disbursements from the GIA under Section 3.3 of the Base Agreement if: (A) the New York Stock Exchange is closed, other than customary weekend and holiday closings, or trading on the New York Stock Exchange is restricted; (B) an emergency exists as a result of which disposal by PRIAC of assets that are underlying investments for the Guaranteed Income Fund is not reasonably practical; or (C) the Securities and Exchange Commission by order permits. The Securities and Exchange Commission shall by rules and regulations determine the conditions under which (i) trading shall be deemed to be restricted and (ii) an emergency shall be deemed to exist. However, during the deferral period We may continue payments to investors ratably as the Guaranteed Income Fund cash flow permits. During the deferral period We will continue to apply Credited Interest. 1.8 TRANSFER LIMITATIONS Transfers between the GIA and a Competing Fund may be made, provided the amount to be transferred is first transferred to a Plan investment option that is not a Competing Fund and such amount is held in that fund for a period of at least ninety (90) days before being transferred to a Competing Fund. A Competing Fund is an investment option available under the Plan that is primarily comprised of high quality fixed income securities with an average duration.of less than or GA -2020 -GIF -FS -0805 25D-57 Addend=457single_PRIAC_2020-GIF-FS-0805 equal to 3.5 years. For purposes of the Agreement, Competing Funds include but are not limited to money market and short term bond funds. We reserve the right, upon 30 days notice, to determine whether any investment option under the Plan is or becomes a Competing Fund. A Prohibited Competing Fund is a money market fund, a fund that guarantees principal or a fund that is primarily comprised of instruments that guarantee principal. You may not offer a Prohibited Competing Fund as a Plan investment option unless We give You prior written consent. 1.9 GIA POOL TRANSFER LIMITATION. The assets under the GIA are part of the Guaranteed Income Fund pool established for all investment agreements containing this or a similar limitation, and where We receive the initial Deposit to the GIA in the same period within the calendar year. We may defer a Distribution or Termination Disbursement whenever (i) plus (ii) would exceed ten percent (10%) of (iii) where (i) is the Distribution or Termination Disbursement amount to be paid from the GIA, (ii) is all Transfer, Distribution, or Termination Disbursement amounts that We previously or simultaneously paid for any reason in the same calendar year in which (i) is computed, from the same pool of Guaranteed Income Fund assets to which the GIA belongs, and (iii) is total assets on January 1 of the year in. which (i) is computed in the Guaranteed Income Fund pool to which the GIA belongs. In addition, We guarantee the following: (A) We will not defer an amount which would result in a Distribution or Termination Disbursement of less than ten percent (10%) of the GIA in any one calendar year. (B) We will continue to apply Credited Interest to any amount We defer under this Section. (C) While the pool transfer limitations of this Section are in effect, as the Plan permits, We will continue to pay Distributions for retirement, termination, death, disability, unforeseen emergency, or Distributions required by Code section 401(a)(9). In addition, as provided under Section 5.4(C) of the Base Agreement, We will pay Termination GA -2020 -GIF -FS -0805 25D-58 Addend=457single_PRIAC_2020-GIF-FS-0805 Disbursements occurring as a result of the Plan's termination or failure to meet the requirements of Code section 457, and the limitations of this Section 1.9 will not apply to such Termination Disbursements. (D) While the pool transfer limitations of this Section are in effect, We will continue to allow Transfers under the terms of the Plan. (E) This Section does not apply if this Agreement has terminated under Section 5 of the Base Agreement. Upon termination, the provisions of the following Section 1.10 will apply. 1.10 TERMINATION TRANSFER LIMITATIONS. If this Agreement terminates under Section 5 of the Base Agreement, the limitations of this Section apply. The assets under the GIA are part of the Guaranteed Income Fund pool established for all investment agreements containing this or a similar limitation, and where We receive the initial Deposit to the Guaranteed Income Fund in the same period within the calendar year. We will disburse the assets under the GIA in a single lump sum as of the Termination Disbursement Date, defined in Section 5.3 of the Base Agreement, if (i) plus (ii) does not exceed ten percent (10%) of (iii) where (i) is the Termination Disbursement amount to be paid from the GIA, (ii) is all Transfer, Distribution, or Termination Disbursement amounts that We previously paid for any reason in the same calendar year in which this Agreement is terminated and from the same pool of Guaranteed Income Fund assets to which the GIA belongs, and (iii) is total assets on January 1 of the year in which (i) is computed in the Guaranteed Income Fund pool to which the GIA belongs. If (i) plus (ii) exceeds ten percent (10%) of (iii), We may apply the following limitations: (A) As of the Termination Disbursement Date, We will disburse an amount equal to the greater of (a) or (b) as follows: (a) is the difference between ten percent (10%) of (iii) above, and (ii) above. (b) is one-sixth (1/6) of the GIA value as of the Termination Disbursement Date. GA -2020 -GIF -FS -0805 4 Addend=457single_PRIAC_2020-GIF-FS-0805 25D-59 On each anniversary of the Termination Disbursement Date, We will disburse assets remaining credited to the GIA in five (5) succeeding annual installments as follows: (1) The first installment is one-fifth (1/5) of the remaining value of the GIA; (2) The second installment is one-fourth (1/4) of the remaining value of the GIA; (3) The third installment is one-third (1/3) of the remaining value of the GIA; (4) The fourth installment is one-half (1/2) of the remaining value of the GIA; (5) The fifth installment is the remaining value of the GIA. We will issue a written guarantee of the interest rate that We will credit to the unpaid balance of the GIA. The interest rate will be an annual rate and will not change during the life of the installment payment period (the "Installment Period Rate"). Installment Period Rate = i -.56-i) where (i) is the Declared Interest Rate applicable to the Guaranteed Income Fund pool to which the GIA belongs as of the Termination Date, defined under Section 5.2 of the Base Agreement, and (j) is the rate of credited interest as of the Termination Date applicable to the Guaranteed Income Fund pool established for the same period within the calendar year in which the Termination Date occurs (the "New Rate"). We will ensure that the New Rate is determined on the same basis as the Declared Interest Rate. The Installment Period Rate will always be greater than or equal to the Minimum Rate in effect during the semi-annual period in which the Termination Date falls, as described in Section 1.3 hereunder. In addition, We will continue to charge Expenses described in the Expense Schedule. The maximum interest rate We will credit is equal to the Declared Interest Rate. Notwithstanding the preceding paragraphs of this Section 1.10(A), We may disburse the remaining balance of the GIA at any time in a single GA -2020 -GIF -FS -0805 25D-60 Addend=457single_PRIAC_2020-GIF-FS-0805 lump sum. (B) Payment Over a Maximum Period of Ten Years. In lieu of the installment payments under the preceding Section 1.10(A), You may direct Us in writing to disburse the assets from the GIA in annual installments over no more than ten (10) years from the Termination Date. The initial disbursement will be on the first anniversary of the Termination Date if that date is a normal business day for Us. If not, the disbursement will be made on PRIAC's next normal business day. Any subsequent disbursements will be made on each calendar year anniversary of the Termination Date if that date is a normal business day for Us. If not, the disbursement will be made on PRIAC's next normal business day. We will issue a written guarantee of the interest rate that We will credit to the unpaid balance of the GIA. The interest rate will be an annual rate and will not change during the life of the installment payment period (the "Installment Period Rate"). Installment Period Rate = Declared Interest Rate as of the Termination Date - 1 % The Installment Period Rate will always be greater than or equal to the Minimum Rate in effect during the semi-annual period in which the Termination Date falls, as described in Section 1.3 hereunder. In addition, We will continue to charge Expenses described in the Expense Schedule. The number of annual payments will be referred to as "N" where N = 04) times 100 rounded up to the next integer but N is not less than 1 or greater than 10, j = the New Rate, and i = the Declared Interest Rate as of the Termination Date. Each disbursement will be an amount equal to 1/(N-t+l) times the remaining value of the GIA, where t equals 1 for the first installment, 2 for the second installment, and so on until it equals N for the last installment. After the Termination Date and during any installment period described in this Section 1. 10, and as the Plan permits, We will continue to pay Distributions for retirement, termination, death, disability, unforeseen emergency, or Distributions required by Code _.._ section 401(x)(9). Also, after the Termination Date, as the Plan permits, Wewill . GA -2020 -GIF -FS -0805 25D-61 Addend=457single_PRIAC_2020-GIF-FS-0805 continue to pay Transfers so long as: (a) the GIA is part of the Plan's stable value investment option and that investment option comprises at least one other investment contract; (b) amounts payable from investment contracts constituting the Plan's stable value option are on a "last in, first out" basis with all other investment contracts being used before the GIA to pay Transfers, i.e., the value of each of the other investment contracts that constitute the Plan's stable value option must be $0 before a Transfer is paid from the GIA and (c) Transfers to a Competing Fund may be restricted in accordance with Section 1.8 of the Addendum. Notwithstanding the foregoing, as provided under Section 5.4(B) and (C) of the Base Agreement, We will pay Termination Disbursements occurring as a result of the Plan's termination or failure to meet the requirements of Code Section 457 in a single lump sum payment, or as You and We mutually agree. We will also pay Termination Disbursements occurring as a result of termination of this Agreement under Section 5.1(D) of the Base Agreement in a single lump sum payment. 1.11 TERMINATION OF GUARANTEED INCOME FUND INVESTMENT ADDENDUM. We may terminate this Investment Addendum upon 90 days' advance notice if. (i) We determine that the continued operation of the Guaranteed Income Fund is no longer commercially desirable for the class of business to which this Agreement belongs, and (ii) We notify all investors belonging to the same class of business as this Agreement and utilizing the Guaranteed Income Fund in writing that We are terminating the Guaranteed Income Fund. The following provisions apply as of the date We terminate the Guaranteed Income Fund as provided above. (A) We will not accept additional Deposits or Transfers into the GIA and We will not make additional Transfers, Distributions, or Termination Disbursements from the GIA, except as provided in (B) and (C) below. (B) We will determine the amount of any outstanding Asset Charge attributable to the GIA, as described in Section 1.4 of this Investment Addendum and the Expense Schedule. We will withdraw the amount from the GIA unless You agree to pay the Asset Charge, as described GA -2020 -GIF -FS -0805 7 Addendum457single_PRIAC_2020-GIF-FS-0805 25D-62 in the Base Agreement. (C) You may transfer the GIA balance in a lump sum to any other investment option represented by an Investment Addendum under this Agreement. We will disburse any remaining GIA balance in a lump sum as You direct in writing. If You do not transfer the GIA balance to another investment option under this Agreement, or otherwise direct Us to disburse the balance, We will transfer the GIA balance to a non- interest bearing account until such time as You transfer the GIA balance to another investment option under this Agreement, or otherwise direct Us to disburse the balance. GA -2020 -GIF -FS -0805 25D-63 Addend=457single_PRIAC_2020-GIF-FS-0805 UNIVERSAL SEPARATE ACCOUNT E INVESTMENT ADDENDUM 1.1 Separate Account E, as referenced in this Addendum, is each pooled separate account maintained by Prudential Retirement Insurance and Annuity Company (PRIAC) that is described in the Appendix to this Addendum. We segregate Separate Account E assets from PRIAC's other assets. Separate Account E assets are only subject to the claims of investors participating in this Separate Account. We maintain and operate Separate Account E in accordance with the following paragraphs. (A) INVESTMENTS. We invest Separate Account E assets as described in the Appendix. We invest each separate account's assets primarily either in (a) publicly issued bonds or common stocks of domestic or non -United States companies or other equity securities of domestic or non -United States companies, or other types of equity investments or debt types of investments, (b) units of other separate accounts that We maintain or (c) interests in other commingled investment funds that invest primarily in either common stocks or other types of equity investments or debt types of investments. However, We may invest the assets in any investment that We deem to be permissible under applicable law. We will invest or reinvest Separate Account E assets at PRIAC's sole discretion. We will credit/charge any income and any realized or unrealized gains or losses under Separate Account E without regard to its other income, gains or losses. (B) SEPARATE ACCOUNT E EXPENSES. We may apply the following expenses to Separate Account E assets. (a) Separate Account Investment Management Fee. This fee covers the investment management of Separate Account E assets. In addition, it covers expenses and taxes that We incur in establishing and maintaining each investment vehicle under this Addendum. We will determine this fee and apply it daily to all investors' assets in Separate Account E. We allocate the fee based on the value of each investor's share of Separate Account E. The maximum aggregate annual rate of Management Fee.will:not exceed one and three -fourth GA -2020 -SAE -0805 25D-64 percent (1.75%). (b) Other Separate Account Expenses. If applicable, We will deduct the following expenses directly from Separate Account E assets: (i) brokerage commissions, transfer taxes and other direct charges arising from the purchase or sale of investments or futures instruments under Separate Account E; (ii) other taxes, charges or expenses directly attributable to the operation of, or the assets held in, Separate Account E; and any expenses (including reasonable fees and expenses for the time spent by officers or employees of PRIAC) that We incur in the course of litigation, representation on any creditors' committees, or any other action that We determine is reasonably necessary or required to preserve or enhance the value of Separate Account assets. (C) SEPARATE ACCOUNT E UNIT. We divide Separate Account E into units of participation and We refer to each unit as a Separate Account E Unit. When We accept Deposits or Transfers into Separate Account E, We increase the number of Separate Account E Units. When We make Transfers, Distributions or Termination Disbursements from Separate Account E, We decrease the number of Separate Account E Units. We determine the increase or decrease in the number of Separate Account E Units by dividing (i) by (ii) where (i) is the amount allocated to or withdrawn from Separate Account E, and (ii) is the then current Separate Account E Unit Value. (D) SEPARATE ACCOUNT E UNIT VALUE. We determine a Separate Account E Unit Value on each Valuation Date. The Unit Value is equal to (i) divided by (ii) where (i) is the Market Value of Separate Account E, and (ii) is the total number of Separate Account E Units. GA -2020 -SAE -0805 2 25D-65 The Separate Account E Unit Value on any date is equal to the amount determined on the Valuation Date coinciding with or last preceding such date. (E) MARKET VALUE OF SEPARATE ACCOUNT E. We will determine the Market Value of Separate Account E for each Valuation Date. On any Valuation Date, We determine the Market Value under PRIAC's established procedures for valuing assets. 1.2 VALUATION. The value of the Plan assets invested in Separate Account E is an amount equal to (i) times (ii) where (i) is the number of Separate Account E Accumulation Units credited to the Plan under this Addendum, and (ii) is the Separate Account E Accumulation Unit Value for the Valuation Date. (A) SEPARATE ACCOUNT E ACCUMULATION UNITS. When We accept a Deposit or Transfer for the Plan into Separate Account E, We credit the Plan with a number of Accumulation Units equal to (i) divided by (ii) where (i) is the Deposit or Transfer amount, and (ii) is the Separate Account E Accumulation Unit Value as of the Valuation Date on which We allocate the Deposit or Transfer amount to Separate Account E. When We make a Transfer, Distribution or Termination Disbursement for.the Plan from Separate Account E, We debit the Plan by the number of Separate Account E Accumulation Units equal to (i) divided by (ii) where (i) is the Transfer, Distribution or Termination Disbursement amount, and (ii) is the Separate Account E Accumulation Unit Value as of the Valuation Date on which We make the Transfer, Distribution or Termination Disbursement from Separate Account E. (B) SEPARATE ACCOUNT E ACCUMULATION UNIT VALUE. The Separate Account E Accumulation Unit Value is the Separate Account E Unit Value adjusted to reflect any applicable Asset Charge described GA -2020 -SAE -0805 25D-66 in the Expense Schedule. (C) VALUATION DATE. A Valuation Date will occur on each day that We are open for business and an orderly financial market exists for investment transactions. We base all transactions processed on a Valuation Date on the value of Separate Account E investments as of the close of the financial market's business day. 1.3 LIMITATIONS. We may apply the following limitations. (A) We may delay any Transfer, Distribution, or Termination Disbursement from Separate Account E for a period of up to thirty (30) days if there is negative cash flow into Separate Account E and if We determine that liquidating investments would adversely affect remaining investors in Separate Account E. In determining whether there is negative cash flow, We will consider all investors' assets in Separate Account E as of the Valuation Date that applies to the Transfer, Distribution or Termination Disbursement. (B) We may defer Transfers, Distributions or Termination Disbursements from Separate Account E under Section 3.3 of the Base Agreement if We determine that the value of a Transfer, Distribution or Termination Disbursement is not possible due to any of the following circumstances: (a) The New York Stock Exchange is closed, other than customary weekend and holiday closings, or trading on the New York Stock Exchange is restricted; (b) An emergency exists as a result of which (i) disposal by PRIAC of assets that are underlying investments for Separate Account E is not reasonably practicable or (ii) it is not reasonably practicable for PRIAC fairly to determine the value of net assets in Separate Account E; or (c) Such other periods as the Securities and Exchange Commission may by order permit for the protection of security holders of a registered investment company that is an underlying investment for Separate Account E. (C) We may restrict a Distribution or Termination Disbursement of any Transfers originally made to Separate Account E in accordance with Section 1.8 of the Guaranteed Income Fund Investment Addendum under this Agreement. GA -2020 -SAE -0805 25D-67 1.4 TERMINATION OF SEPARATE ACCOUNT E. We may terminate Separate Account E if (a) We determine that the continued operation of Separate Account E is no longer commercially desirable, and (b) We notify all investors utilizing Separate Account E in writing that We are terminating Separate Account E. The following provisions apply as of the date We terminate Separate Account E. (A) We will not accept additional Deposits or Transfers into Separate Account E and We will not make additional Transfers, Distributions or Termination Disbursements from Separate Account E, except as provided in (B) and (C) below. (B) We will determine the amount of any outstanding Separate Account E Expenses, described in the preceding Section 1.1(B), and withdraw the amount from Separate Account E. We will also determine the amount of any outstanding Asset Charge attributable to Separate Account E and described in the Expense Schedule. We will withdraw the amount from Separate Account E unless You agree to pay the Asset Charge, as provided under Section 4.6 of the Base Agreement. (C) You may transfer the Plan assets invested in Separate Account E to any other investment option represented by an Addendum under this Agreement. We will disburse the remaining value of the Plan assets invested in Separate Account E as You direct in writing. GA -2020 -SAE -0805 25D-68 UNIVERSAL SEPARATE ACCOUNT E APPENDIX This Appendix references each Separate Account that We offer under the Universal Separate Account E Investment Addendum as follows: Separate Separate Investments Account Account Name SA -11 Core Bond/PIM Fund Fund of funds invested in high-quality domestic fixed income securities SA -12 Core Bond Enhanced Index/PIM Fund Invested in a portfolio of fixed income securities that mirrors the composition of the Barclays Capital U.S. Aggregate Bond Index SA -14 Investment Grade Corporate Invested in investment grade, publicly Bond/PIM Fund traded U.S. dollar-denominated corporate bonds SA -15 Corporate Bond/PIM Fund Invested in publicly traded U.S. dollar-denominated corporate bonds SA -16 High Grade Bond/GSAM Fund Invested in investment grade, publicly -traded U.S. and non -U.S. dollar-denominated government and corporate fixed income securities SA -18 Core Plus Bond/Reams Fund Invested primarily in high-quality U.S. and non -U.S. government and corporate fixed income securities SA -55A Fidelity Advisor Growth Wholly invested in the Fidelity Opportunities Account (Class T Advisor Growth Opportunities Fund, a Shares) mutual fund SA -55B Fidelity Advisor Balanced Account Wholly invested in the Fidelity (Class T Shares) Advisor Balanced Fund, a mutual fund SA -55C Fidelity Advisor Value Strategies Wholly invested in the Fidelity Account (Class T Shares) Advisor Value Strategies Fund, a mutual fund SA -55E Credit Suisse Large Cap Blend II Wholly invested in the Credit Suisse (A Shares) Large Cap Blend II, a mutual fund SA -55F Aberdeen International Equity Fund Wholly invested in the Aberdeen (Class R) International Equity Fund, a mutual fund SA -SSG Credit Suisse Large Cap Blend III (A Wholly invested in the Credit Suisse Shares) Large Cap Blend III, a mutual fund GA -2020 -SAE -0805 25D-69 Separate Separate Investments Account Account Name SA -55I Fidelity Advisor Equity Growth Fund Wholly invested in the Fidelity Advisor Equity Growth Fund, a mutual fund SA -55J Invesco Diversified Dividend Fund Wholly invested in the Invesco (Investor Shares) Diversified Dividend Fund, a mutual fund SA -55K Balanced Fund I/Wellington Invested in a combination of equity Management Fund and fixed income securities SA -55M Fidelity Disciplined Equity Account Wholly invested in the Fidelity Disciplined Equity Fund, a mutual fund SA -55N Fidelity Contrafund® Account Wholly invested in the Fidelity Contrafund®, a mutual fund SA -55P Fidelity Equity -Income II Account Wholly invested in the Fidelity Equity -Income II Fund, a mutual fund SA -55Q Fidelity Puritan® Account Wholly invested in the Fidelity Puritan® Fund, a mutual fund SA -55R Fidelity Growth & Income Account Wholly invested in the Fidelity Growth & Income Portfolio, a mutual fund SA -55S Credit Suisse Large Cap Blend I (A Wholly invested in the Credit Suisse Shares) Large Cap Blend I, a mutual fund SA -55W American Century Heritage Account Wholly invested in the American (Investor Shares) Century Heritage Fund, a mutual fund SA -55X American Century Ultra Account Wholly invested in the American (Investor Shares) Century Ultra Fund (Investor Shares), a mutual fund SA -55Y Fidelity Magellan® Account Wholly invested in the Fidelity Magellan® Fund, a mutual fund SA -55Z Fidelity Asset Manager(SM) 50% Wholly invested in the Fidelity Asset Fund Manager 50% Fund, a mutual fund SA-5AC American Century Equity Income Wholly invested in the American Fund (Investor Shares) Century Equity Income Fund, a mutual fund GA -2020 -SAE -0805 25D-70 Separate Separate Investments Account Account Name SA-5AE American Century Real Estate Fund Wholly invested in the American (Class A) Century Real Estate Fund, a mutual fund SA-5AL SA/Alger Mid Cap Growth Strategy Invested primarily in equity securities of U.S. and non-U.S. mid-sized companies SA-5AM SA/Alger Mid Cap Growth Strategy II Invested in units of PRIAC separate account SA-5AL SA-5AR American Century Real Estate Fund Wholly invested in the American (Investor Shares) Century Real Estate Fund, a mutual fund SA-5AS SA/Invesco Small Cap Growth Invested primarily in equity securities Strategy of U.S. small -sized corporations SA-5BY Invesco Charter Account (A Share) Wholly invested in the Invesco Charter Fund, a mutual fund SA-5CS Cohen & Steers Realty Income Fund Wholly invested in the Cohen & (Class I Shares) Steers Realty Income Fund, a mutual fund SA-5CV Calvert Equity Portfolio Wholly invested in the Calvert Equity Portfolio, a mutual fund SA-5CX Invesco Constellation Fund (A Share) Wholly invested in the Invesco Constellation Fund, a mutual fund SA-5DH Diamond Hill Small Cap Fund (Class Wholly invested in the Diamond Hill A Shares) Small Cap Fund, a mutual fund SA-5DW SA/Janus Fund's Strategy Invested primarily in equity securities of U.S. and non-U.S. corporations SA-5DX Janus Fund (S Shares) Wholly invested in the Janus Fund - S Shares, a mutual fund SA-5DZ SA/Janus Balanced Strategy Invested in equity and debt securities of U.S. and non-U.S. corporations SA -5E1 Lazard U.S. Strategic Equity Portfolio Wholly invested in the Lazard U.S. (Open Shares) Strategic Equity Portfolio of the Lazard Funds, Inc., a mutual fund GA -2020 -SAE -0805 25D-71 Separate Separate Investments Account Account Name SA -5E2 Lazard International Equity Account Wholly invested in the Lazard (Open Shares) International Equity Portfolio of the Lazard Funds, Inc., a mutual fund SA -5E3 Lazard U.S. Small -Mid Cap Equity Wholly invested in the Lazard U.S. (Open Shares) Small -Mid Cap Equity Portfolio of the Lazard Funds, Inc., a mutual fund SA -5E4 Lazard U.S. Mid Cap Equity (Open Wholly invested in the Lazard Mid Shares) Cap Portfolio of the Lazard Funds, Inc., a mutual fund SA-5EL Large -Cap Value / Eaton Vance Fund Invested in a portfolio of individual securities SA-5EV Janus Worldwide Fund (T Shares) Wholly invested in the Janus Worldwide Fund, T Shares, a mutual fund SA-5EW Janus Worldwide Fund (Class S Wholly invested in the Janus Shares) Worldwide Fund - S Shares, a mutual fund SA -5171 Janus Forty Fund (A Shares) Wholly invested in the Janus Adviser Forty Fund, a mutual fund SA -5172 Janus Forty Fund (R Shares) Wholly invested in the Janus Adviser Forty Fund, a mutual fund SA-5FU Old Mutual Focused Fund (Class Z Wholly invested in the Old Mutual Shares) Focused Fund, a mutual fund SA -517V American Century Ultra (A Shares) Wholly invested in the American Century Ultra Fund, a mutual fund SA-5GF Franklin Balance Sheet Investment Wholly invested in the Franklin Fund (Class A Shares) Balance Sheet Investment Fund, a mutual fund SA-5GI Goldman Sachs High Yield Fund Wholly invested in the Goldman (Class I Shares) Sachs High Yield Fund, a mutual fund SA-5GM B1ackRock Global SmallCap Fund, Wholly invested in the B1ackRock Inc. (Investor A Shares) Global SmallCap Fund, Inc., a mutual fund SA-5GN B1ackRock Global SmallCap Fund, Wholly invested in the B1ackRock Inc. (Class R Shares) Global SmallCap Fund, Inc., a mutual fund SA-5GS Goldman Sachs Small Cap Value Wholly invested in the Goldman Fund (Class A Shares) Sachs Small Cap Value Fund, a mutual fund GA -2020 -SAE -0805 25D-72 Separate Separate Investments Account Account Name SA-5GT SA/Templeton Growth Strategy Invested primarily in equity securities of U.S. and non -U.S. corporations SA-5GV Goldman Sachs Small Cap Value Wholly invested in the Goldman Fund (Institutional Class) Sachs Small Cap Value Fund, a mutual fund SA-5GY Goldman Sachs High Yield Fund Wholly invested in the Goldman (Class A Shares) Sachs High Yield Fund, a mutual fund SA-51IS SA/Templeton Foreign Strategy Invested primarily in equity securities of non -U.S. corporations SA-5HW Hotchkis and Wiley Large Cap Value Wholly invested in the Hotchkis and Fund (Class A Shares) Wiley Large Cap Value Fund, a mutual fund SA -512 QMA Small Cap Blend Enhanced Invested primarily in QMA U.S. Index Fund Small Cap Equity Fund of the Prudential Trust Company Collective Trust, a collective trust fund SA-5IB QMA International Developed Invested primarily in The Prudential Markets Index Fund Insurance Company of America Variable Investment Account -16 SA-5JR Dreyfus Equity Growth Fund (A Wholly invested in the Dreyfus Equity Shares) Growth Fund, a mutual fund SA-5KI Invesco Basic Balanced Fund Underlying mutual fund sponsored (Investor Shares) and advised by Invesco SA-5KQ Dreyfus Lifetime Growth & Income Wholly invested in the Dreyfus Fund (Investor Class) Lifetime Growth & Income Fund, a mutual fund SA -5L1 Invesco Technology Fund (Investor Wholly invested in the Invesco Share) Technology Fund - Investor Share, a mutual fund SA-5LA Lord Abbett Affiliate Fund (Class P Wholly invested in the Lord Abbett Shares) Affiliated Fund, a mutual fund GA -2020 -SAE -0805 25D-73 Separate Separate Investments Account Account Name SA-5LS Lord Abbett Small Cap Blend Fund Folly invested in the Lord Abbett (Class P Shares) Small Cap Blend Fund, a mutual fund SA -5M1 INVESCO U.S. Mid Cap Value Wholly invested in the MSIF Trust Portfolio (A Share) Mid Cap Value Portfolio, a mutual fund SA-5MI MFS International Growth Fund Wholly invested in the MFS (Class A Shares) International Growth Fund, a mutual fund SA-5MN Neuberger & Berman Guardian Wholly invested in the Neuberger & Account Trust Class Berman Guardian Trust Class, a mutual fund SA-5MV Marshall Mid -Cap Value Fund Wholly invested in the Marshall Mid - (Investor Shares) Cap Value Fund, a mutual fund SA -5N1 AllianceBemstein Balanced Shares Wholly invested in the Fund (Class A Shares) AllianceBernstein Balanced Shares Fund, a mutual fund SA -5N2 AllianceBernstein Growth & Income Wholly invested in the Fund (Class A Shares) AllianceBemstein Growth & Income Fund, a mutual fund SA -5N8 AllianceBemstein Global Value Fund Wholly invested in the (Class A Shares) AllianceBernstein Global Value Fund, a mutual fund SA-5NA AllianceBemstein International Value Wholly invested in the Fund (Class R Shares) AllianceBemstein International Value Fund, a mutual fund SA-5NM Neuberger Berman Partners Fund Wholly invested in the Neuberger & Trust Class Berman Partners Fund Trust Class, a mutual fund SA-5NN AllianceBemstein International Value Wholly invested in the Fund (Class K Shares) AllianceBemstein International Value Fund, a mutual fund SA-5NV Columbia International Value Fund Wholly invested in the Columbia (Class A) International Value Fund, a mutual fund SA-5NY SA/Davis New York Venture Strategy Invested primarily in equity securities of U.S. and non -U.S. large-sized corporations GA -2020 -SAE -0805 25D-74 Separate Separate Investments Account Account Name SA -501 Oakmark Select Fund (Class I Shares) Wholly invested in the Oakmark Select Fund, a mutual fund SA -502 Oakmark Select Fund (Class II Wholly invested in the Oakmark Shares) Select Fund, a mutual fund SA -503 SA/Oakmark Equity & Income Invested primarily in equity and fixed Strategy income securities SA -504 SA/Oakmark Equity & Income Invested in units of PRIAC separate Strategy II account SA -503 SA-5OD Oppenheimer Developing Markets Wholly invested in the Oppenheimer Fund (Class A Shares) Developing Markets Fund, a mutual fund SA-5OG SA/OFII Global Strategy Invested primarily in equity securities of U.S. and non -U.S. corporations SA-5OP SA/OFII Capital Appreciation Invested primarily in equity securities Strategy of U.S. and non -U.S. corporations SA-5OS Oppenheimer Small & Mid -Cap Wholly invested in the Oppenheimer Value Fund (Class A Shares) Small & Mid Cap Value Fund, a mutual fund SA-5PM Pioneer Mid Cap Value Fund (Class A Wholly invested in the Pioneer Mid Shares) Cap Value Fund, a mutual fund SA-5PV Pioneer Mid Cap Value Fund (Class R Wholly invested in the Pioneer Mid Shares) Cap Value Fund, a mutual fund SA-5QJ Invesco Dynamics Fund (Investor Wholly invested in the Invesco Share) Dynamics Fund, a mutual fund SA-5RH Fidelity Advisor Equity Income Wholly invested in the Fidelity Account (Class T Shares) Advisor Equity Income Fund, a mutual fund SA -5S1 SA/Wells Fargo Small Cap Value Invested in units of PRIAC separate Strategy II account SA -5S2 SA -5S2 SA/Wells Fargo Small Cap Value Invested primarily in common stocks Strategy ' and other equity -related securities GA -2020 -SAE -0805 25D-75 Separate Separate Investments Account Account Name SA -5S3 Wells Fargo Advantage Opportunity Wholly invested in the Wells Fargo Fund (Investor Shares) Advantage Opportunity Fund, a mutual fund SA -5S4 Wells Fargo Advantage Opportunity Wholly invested in the Wells Fargo Fund (Class A Shares) Advantage Opportunity Fund, a mutual fund SA -5T1 T. Rowe Price Blue Chip Growth Wholly invested in the T.Rowe Price Fund (Advisor Shares) Blue Chip Growth Fund, a mutual fund SA -5T2 SANT. Rowe Price Equity Income Invested primarily in equity securities Strategy of established U.S. companies SA -5T3 T. Rowe Price Small Cap Stock Fund- Wholly invested in the T.Rowe Price (Advisor Shares) Small Cap Stock Fund, a mutual fund SA -5T4 T. Rowe Price Blue Chip Growth Wholly invested in the T. Rowe Price Fund (R Shares) Blue Chip Growth Fund, a mutual fund SA -5T5 SANT. Rowe Price Equity Income Invested in units of PRIAC separate Strategy II account SA -5T2 SA -5T6 SA/T. Rowe Price Growth Stock Invested in common stocks and other Strategy equity -related securities SA -5T7 SANT. Rowe Price Growth Stock Invested in units of PRIAC separate Strategy II account SA -5T6 SA-5TE Prudential TIPS Enhanced Index Fund Invested primarily in Prudential Inflation Protected Securities Fund of the Prudential Trust Company Collective Trust, a collective trust fund SA-5TG Thornburg Core Growth Fund (R3 Wholly invested in the Thornburg Shares) Core Growth Fund, a mutual fund GA -2020 -SAE -0805 25D-76 Separate Separate Investments Account Account Name SA -5TH Thornburg International Value Fund Wholly invested in the Thornburg (Class R3 Shares) International Value Fund, a mutual fund SA-5TM Turner Mid Cap Growth Fund (Class I Wholly invested in the Turner Mid Shares) Cap Growth Fund, a mutual fund SA -5V2 Vanguard® Wellington Account Wholly invested in the Vanguard® (AdmiralTM Shares) Wellington Fund, a mutual fund SA -5V3 Vanguard®Growth and Income Wholly invested in the Vanguard® Account (AdmiralTM Shares) Growth and Income Fund, a mutual fund SA -5V4 Vanguard® Balanced Index Account Wholly invested in Vanguard® (AdmiralTM Shares) Balanced Index Fund, a mutual fund SA-5VD Victory Diversified Stock Fund Wholly invested in Victory (Class A Shares) Diversified Stock Fund, a mutual fund SA-5Wl SA/Waddell & Reed Accumulative Invested primarily in equity securities Strategy of U.S. corporations SA -5W2 Ivy Small Cap Growth Fund (Class Y Wholly invested in the Ivy Small Cap Shares) Growth Fund, a mutual fund SA -5W3 Waddell & Reed Advisors Science & Folly invested in the Waddell & Technology Fund (Class A Shares) Reed Advisors Science and Technology Fund,a mutual fund SA -5X1 American Century International Wholly invested in the American Growth Account (Investor Shares) Century International Growth Fund, a mutual fund SA -5X2 Manning & Napier Pro -Blend Wholly invested in the Manning & Moderate Term Series Class S Napier Pro -Blend Moderate Term Fund, a mutual fund SA -5X3 Manning & Napier Pro -Blend Wholly invested in the Manning & Extended Term Series Class S Napier Pro -Blend Extended Term Fund, a mutual fund SA -5X4 Manning & Napier Pro -Blend Wholly invested in the Manning & Conservative Term Series Class S Napier Pro -Blend Conservative Term Fund, a mutual fund GA -2020 -SAE -0805 25D-77 Separate Separate Investments Account Account Name SA -5X5 Manning & Napier Pro -Blend Wholly invested in the Manning & Maximum Term Series Class S Napier Pro -Blend Maximum Term Fund, a mutual fund SA -9V Large Cap Blend/Victory Fund Invested in common stocks and other equity -related securities SA -9W Large Cap Blend/AJO Fund Invested in common stocks and other equity -related securities SA-AI2 International Blend / Artio II Invested primarily in equity -related securities of non -U.S. companies SA -B Dryden S&P 5000 Index Fund Invested in a portfolio of common stocks that mirrors the composition of the S&P 5009) Index SA-B2F Balanced/Turner Investment Partners, Invested in units of other PRIAC PIM Fund separate accounts that invest in domestic equity, fixed income and cash equivalent instruments SA -13417 Balanced/Wellington Mgmt., PIM Invested in units of other PRIAC Fund separate accounts that invest in domestic equity, fixed income and cash equivalent instruments SA-B5F Balanced Growth / American Century, Invested in equity and fixed income GSAM Fund securities SA -13172 Balanced/Turner Investment Partners, Invested in units of other PRIAC PIM Fund separate accounts that invest in domestic equity, fixed income and cash equivalent instruments SA-BF3 Balanced/Dresdner RCM Fund Invested in equity and fixed income securities SA-BF4 Balanced/Wellington Mgmt., PIM Invested in units of other PRIAC Fund separate accounts that invest in domestic equity, fixed income and cash equivalent instruments GA -2020 -SAE -0805 25D-78 Separate Separate Investments Account Account Name SA-BF5 Balanced Growth / American Century, Invested in units of other PRIAC GSAM Fund separate accounts that invest in equity and fixed income securities International Blend / AQR Invested in common stocks and other SA-BIA equity -related securities of non -U.S. companies SA -BSC Small Cap Value / American Century Invested in common stocks and other Fund equity -related securities SA -BSS Prudential IncomeFlex Select Units of other PRIAC separate EasyPath Balanced Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -CG Large Cap Growth/Goldman Sachs Invested in common stocks and other Fund equity -related securities SA -CII Bache Commodities Total Return Invested primarily in commodities and Fund US Treasury securities SA -CPP Core Plus Bond/PIMCO Fund Invested in a diversified portfolio of fixed income securities SA -CSF High Yield Bond/Caywood-Scholl Invested in a diversified portfolio of Fund high -yield fixed income securities SA -CV Large Cap Value/AJO Fund Invested in common stocks and other equity -related securities SA -EMG QMH' Emerging Markets Fund Invested in equity securities of emerging market countries GA -2020 -SAE -0805 25D-79 Separate Separate Investments Account Account Name SA-FTF Small Cap Growth/TimesSquare Fund Invested in common stocks and other equity -related securities SA-GB1 Government Securities/PIM Fund Invested in debt Securities guaranteed or otherwise backed by the U.S. Government SA -I Dryden International Equity Fund Invested in common stock and other equity -related securities of non -U.S. companies SA -I132 International Blend/Pictet Asset Invested in common stock and other Management Fund equity -related securities of non -U.S. companies SA-IBT International Blend/Thomburg Fund Invested in common stock and other equity -related securities of non -U.S. companies SA-IE2 International Blend/Artio Fund Invested primarily in securities of non -U.S. companies SA-IG2 International Growth/ Artisan Partners Invested primarily in common stocks Fund and other equity -related securities SA-IVI International Value/LSV Asset Invested in common stocks and other Management Fund equity -related securities SA405 Target Milestones 2005 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate GA -2020 -SAE -0805 25D-80 Separate Separate Investments Account Account Name SA -J10 Target Milestones 2010 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA415 Target Milestones 2015 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA420 Target Milestones 2020 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA425 Target Milestones 2025 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate GA -2020 -SAE -0805 25D-81 Separate Separate Investments Account Account Name SA430 Target Milestones 2030 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA435 Target Milestones 2035 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA440 Target Milestones 2040 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA445 Target Milestones 2045 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate GA -2020 -SAE -0805 25D-82 Separate Separate Investments Account Account Name SA450 Target Milestones 2050 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA455 Target Milestones 2055 Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -JIT Target Milestones Income Fund Units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -LI Lifetime Aggressive Growth Fund" Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments 80% in common stock and other equity investments 20% in debt es of investments GA -2020 -SAE -0805 25D-83 Separate Separate Investments Account Account Name SA -L2 Lifetime Growth Fund** Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments 70% in common stock and equity investments 30% in debt types of investments SA -L3 Lifetime Balanced Fund** Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments 65% in common stock and other equity investments 35% in debt types of investments SA -L4 Lifetime Conservative Growth Invested in units of other PRIAC Fund** separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments 55% in common stock and other equity investments 45% in debt types of investments SA -L5 Lifetime Income & Equity Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments GA -2020 -SAE -0805 25D-84 Separate Separate Investments Account Account Name SA -L9 Prudential/Lazard Lifestyle20 Fund" Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments 35% in common stock and other equity investments 65% in debt types of investments SA-LB3 Large Cap Blend Enhanced Index/QM Invested primarily in common stock Fund and other equity -related securities SA-LB4 QMA US Broad Market Index Fund Invested primarily in common stock and other -equity -related securities SA-LC2 Large Cap Growth/ Turner Investment Invested in common stocks and other Partners Fund equity -related securities SA -LDC Prudential Long Duration Corporate Invests in a diversified portfolio of Bond Fund fixed income securities SA-LG3 Large Cap Growth / American Invested in common stocks and other Century equity -related securities SA-LG5 Large Cap Growth/Neuberger Berman Invested in common stocks and other eq ui -related securities SA-LG6 Large Cap Growth/Jennison Fund Invested primarily in equity and equity -related securities of large-sized companies SA -LPO Retirement Goal Income Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments GA -2020 -SAE -0805 25D-85 Separate Separate Investments Account Account Name SA -LPI Retirement Goal 2010 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments SA-LP2 Retirement Goal 2020 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments SA-LP3 Retirement Goal 2030 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments SA-LP4 Retirement Goal 2040 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments SA-LP5 Retirement Goal 2050 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments SA -LSO Retirement Goal Income Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or fixed income investments GA -2020 -SAE -0805 25D-86 Separate Separate Investments Account Account Name SA -LS 1 Retirement Goal 2010 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments SA-LS2 Retirement Goal 2020 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments SA-LS3 Retirement Goal 2030 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments SA-LS4 Retirement Goal 2040 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments SA-LS5 Retirement Goal 2050 Fund Invested in units of other PRIAC separate accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments SA-LV3 Large Cap Value Fund (sub -advised Invested in common stocks and other by Wellington Management) equity -related securities SA-LV4 Large Cap Value/Barrow Hanley Invested in common stocks and other Fund equity -related securities SA-LV5 Large Cap Value/LSV Asset Invested in equity securities of large Management Fund capitalization corporations GA -2020 -SAE -0805 25D-87 Separate Separate Investments Account Account Name SA-LV7 Large Cap Value / The Boston Invested primarily in common stocks Company Fund and other equity -related securities SA-MB4 Mid Cap Blend Enhanced Index/QM Invested primarily in common stocks Fund and other equity -related securities SA -MCG Mid Cap Blend/Batterymarch Fund Invested in common stocks and other equity -related securities SA -MGI Mid Cap Growth/Artisan Partners Invested in common stocks and other Fund equity -related securities SA-MG3 Mid Cap Growth/fimesSquare Fund Invested in securities of mid -cap corporations rated at the time of purchase SA-MG4 Mid Cap Growth/Goldman Sachs Invested primarily in equity and Fund equity -related securities of mid-sized companies SA-MG5 Mid Cap Growth/Frontier Capital Invested primarily in equity and Fund equity -related securities of mid-sized companies SA-MG6 Mid Cap Growth/Westfield Capital Invested primarily in equity and Fund equity -related securities of mid-sized companies SA -MVI Mid Cap Value Fund (sub -advised by Invested in common stocks and other Wellington Management) equity -related securities SA-MV2 Mid Cap Value/Cooke & Bieler Fund Invested primarily in equity and equity -related securities of mid-sized companies SA-MV3 Mid Cap Value/CRM Fund Invested primarily in equity and equity -related securities of mid-sized companies SA-MV4 Mid Cap Value/Integrity Fund Invested primarily in equity and equity -related securities of mid-sized companies GA -2020 -SAE -0805 r :: Separate Separate . Investments Account Account Name SA-MV5 Mid Cap Value / Columbia Fund Invested primarily in common stocks of mid-sized companies SA-MV6 Mid Cap Value/Systematic Fund Invested primarily in common stocks of mid-sized companies SA -RFI Morally Responsible Core Plus Invested in a broad array of fixed Bond/PIMCO Fund income securities SA-RLG Morally Responsible Large Cap Invested primarily in equity and Growth/Turner Fund equity -related securities of large-sized companies SA-RLV Morally Responsible Large Cap Invested primarily in equity and Value/AJO Fund equity -related securities of large-sized companies SA -SBI Small Cap Blend/WHV Fund Invested in common stocks and other equity -related securities SA-SB3 Jennison Small Cap Core Equity Invested primarily in common stocks of small sized companies SA -SCS Prudential IncomeFlex Select Units of other PRIAC separate EasyPath Conservative Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA-SG3 Small Cap Growth / The Boston Co. Invested in common stocks and other Fund equity -related securities SA-SG5 Small Cap Growth/Essex Fund Invested in common stocks and other equity -related securities GA -2020 -SAE -0805 25D-89 Separate Separate Investments Account Account Name SA-SG6 Small Cap Growth/EIM Fund Invested primarily in equity related securities of small -sized companies SA-SG7 Small Cap Growth/Columbus Circle Invested in common stocks and other Fund equity related securities SA-SG8 Small Cap Growth/Turner Fund Invested in common stocks and other equity related securities SA-SGI TimesSquare Small Cap Growth Underlying mutual fund sponsored by (Institutional Shares) CIGNA and advised by TimesSquare Capital Management, LLC SA -SGP TimesSquare Small Cap Growth Underlying mutual fund sponsored by (Premier Shares) CIGNA and advised by TimesSquare Capital Management, LLC SA -SMS Prudential IncomeFlex Select Units of other PRIAC separate EasyPath Moderate Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA-SV2 Small Cap Value/TS&W Fund Invested in common stocks and other equity -related securities SA-SV3 Small Cap Value/Kennedy Capital Invested in common stocks and other Fund equity -related securities SA-SV4 Small Cap Value / TBCAM Invested in common stocks and other equity -related securities SA-SV5 Small Cap Value/Integrity Fund Invested in common stocks and other equity -related securities SA-SV6 Small Cap Value/Opus Capital Fund Invested in common stocks and other equity -related securities SA-SV7 Small Cap Value / AmCent II Invested in common stocks and other equity -related securities GA -2020 -SAE -0805 25D-90 Separate Separate Investments Account Account Name SA-SV8 Small Cap ValueNictory Fund Invested in common stocks and other equity -related securities SA -T10 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2010 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T15 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2015 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T20 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2020 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T25 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2025 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate GA -2020 -SAE -0805 25D-91 Separate Separate Investments Account Account Name SA -T30 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2030 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T35 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2035 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T40 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2040 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T45 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2045 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T50 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2050 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate GA -2020 -SAE -0805 25D-92 Separate Separate Investment's Account Account Name SA -T55 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2055 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -T60 Prudential IncomeFlex Target Units of other PRIAC separate EasyPath 2060 Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate SA -TBS Prudential IncomeFlex Target Units of other PRIAC separate EasyPath Balanced Fund accounts or interests in other commingled investment funds that invest primarily in either common stocks or other types of equity or debt investments with some investments in non-traditional asset classes such as commodities and real estate Additional information regarding these Account(s) is available upon request. "Please note that percentages listed under Investments are based on estimates We use for illustrative purposes and do not necessarily reflect the actual allocation as of the Effective Date of the Agreement or any prospective date. We can provide You additional information regarding current percentages that apply to these funds. GA -2020 -SAE -0805 25D-93 25D-94